There doesn't need to be a victim in a civil case.
Who is the victim when you are charged with speeding or reckless driving?
The state is punishing me for breaking the law with a reasonable fine commensurate to the crime to deter me from potentially harming others with such behavior in the future since "speed kills" and for sure reckless driving does.
Don't you find it odd he is the first person to have the statute applied like this in ever? Since his actions harmed or even potentially harmed no one, what behavior are they deterring with such a huge fine? According to all sources, his actions were the norm in large real estate transactions. The owner provides their valuation, and the lender has the choice to accept it or determine their own.
Are we saving the banks, all of whom made their money back? Are we saving the citizens, who had no skin in this game anyway? Who are we protecting with this action? Since that's the purpose of law, to ensure behavior does not harm others, right?
Face it, the only reason for this suit is that they dont want him to be President again. And of course, they need to punish him for having the temerity to become President before. He must be crushed to set an example.
What's funny is that I dont even like the man. But seeing this veritable fleet of of busses they are trying desperately to stuff him under is pretty nuts.