Epstein Secrets

i- rected activities where defendant delivered products into stream of commerce with ex- pectation they would be purchased by resi- dents of forum); Calder, 465 U.S. at 789- 90, 104 S.Ct. 1482 (fording publishing ac- tivities outside of forum were calculated to cause injury to plaintiff in forum where

m, and the litigation results from al- leged injuries that arise out of or related to those activities"). Pursuant to the hold- ings in Thayer King, Calder, and three recent terrorism cases—Rein v. Socialist People's Libyan Arab Jamahiriya, 995 F.Supp. 325 (E.D.N.Y.1998), Daliberti v. Republic of Ira

plaints name the Saudi Binladin Group ("SBG") as a Defendant. The Burnett complaint also names Tariq Binladin, Omar Binladin, and Bakr Binlaclin, Osama's half-brothers, as Defendants. In both actions, these Defen- dants move to dismiss the complaint or for a more definite statement. Based in Jedda

minimum contacts existed since dispute arose from a contract with substantial con- tacts with the forum) (internal quotations and citations omitted); Calder v. Jones, 465 U.S. 783, 789, 104 S.Ct. 1482, 79 L.Ed.2d 804 (1984) (finding personal juris- diction appropriate over non-resident de- fendants who “e

tates. Accordingly, Plaintiffs may rely on their “purposefully directed” theory to establish these mini- mum contacts. But as existed in Burger King, Calder, and the three terrorism cases, Plaintiffs must allege some personal or direct involvement by the Defendants in the conduct giving rise to their clai

complaints name the Saudi Binladin Group (““SBG”) as a Defendant. The Burnett complaint also names Tariq Binladin, Omar Binladin, and Bakr Binladin, Osama’s half-brothers, as Defendants. In both actions, these Defen- dants move to dismiss the complaint or for a more definite statement. Based in Jeddah,

nt took ‘intentional * * * tortious, actions’ and ‘knew that the brunt of th[e] injury would be felt’ in the *15 foreign forum.” Jd. at *19, (quoting Calder v. Jones, 465 U.S. 783, 789-790 (1984)). Even so, the United States argued that the questions presented by the Petition did not warrant review by the

bin Mahfouiz and Suleiman al Rajhi, are identified as primary al-Qaeda financiers in the Golden Chain.” Bakr, Tariq, Omar, and Yeslam bin Laden are Osama’s half-brothers. Bakr, Tariq, and Omar are alleged to have used their positions within the Saudi Binladin Group, the bin Laden family construction em