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liat- ed. These contacts are not sufficiently "systematic and continuous" to maintain general jurisdiction over a defendant in this action.8' See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in foru
ned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 11325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-d
affiliat- ed. These contacts are not sufficiently “systematic and continuous” to maintain general jurisdiction over a defendant in this action.** See Helicopteros, 466 U.S. at 416, 104 S.Ct. 1868 (holding that purchas- ing in forum, sending personnel for train- ing in forum, and negotiating a contract in forum
Page: HOUSE_OVERSIGHT_017881 →-owned subsidiary of SBG and its board members include defen- dants Bakr, Tariq, and Omar Binladin. Ashton Complaint 1556; Burnett Com- plaint 91325. Khalifa listed the Mo- hammed Bin Laden Organization address on his visa application. Ashton Complaint 1555; Burnett Complaint 1324. Addition- ally, U.S.-des
Page: HOUSE_OVERSIGHT_017887 →ownership of shares m Texas corporations, on its own, cannot be considered sufficiently systematic and continuous to establish general jurisdiction. Helicopteros, 466 U.S. at 414-16, 104 S.Ct. 1868 (finding CEO’s travel to forum for contract negotiations, employees’ travel to forum for training, receipt of fun
Page: HOUSE_OVERSIGHT_017922 →lippines office, which served as a center of terrorist financing and training. (Ashton Compl. § 310; Burnett Compl. § 234; Federal Compl. §§ 135-36.) Khalifa collected and laundered money for al Qaeda through ITRO’s Phillipines office. (Ashton Compl. J 316; Burnett Compl. J 240.) Through Khalifa, TRO was a
Page: HOUSE_OVERSIGHT_017924 →Entities connected to both Helicopteros and Khalifa

United States
LOCATION
Bill Clinton
PERSON
Lebanon
LOCATION
Michael Cohen
PERSON
al-Qaeda
ORGANIZATION
Supreme Court
ORGANIZATION
Riyadh
LOCATION
Saudi Arabia
LOCATION
Osama bin Laden
PERSON
Somalia
LOCATION
Yemen
LOCATION
Alfredo Rodriguez
PERSONthe Council of Ministers
ORGANIZATION
United Kingdom
LOCATIONSecond Circuit
ORGANIZATION
Kenya
LOCATION
Houston
LOCATION
Philadelphia
LOCATION
New York
LOCATIONBurnett
PERSON