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er, "courts, including the Second Circuit, have almost unanimously permitted actions premised on a theory of aiding and abetting and conspiracy." Presbyterian Church of Sudan a Talis- man Energy, Ina, 244 F.Supp2d 289, 311 (S.D.N.Y.2003). Accordingly, the ATCA may provide a basis for a concerted action claim of materia
that a plaintiff "must demonstrate that the defendant has sufficient minimum contacts to satisfy a traditional due process analysis." Estates of Ungar a Palestinian Autlk, 153 F.Supp2d 76, 95 (D.R.I.2001); see also Biton v. Palestinian Interim Self-Gov% Auth., 310 F.Supp.2d 172, 179 (D.D.C. 200
uded that a plaintiff “must demonstrate that the defendant has sufficient minimum contacts to satisfy a traditional due process analysis.” Estates of Ungar v. Palestinan Auth, 153 F.Supp.2d 76, 95 (D.R.1.2001); see also Biton v. Palestinian Interim Self-Gov't Auth. 310 F.Supp.2d 172, 179 (D.D.C. 2004) (d
Page: HOUSE_OVERSIGHT_017871 →urther, “courts, including the Second Circuit, have almost unanimously permitted actions premised on a theory of aiding and abetting and conspiracy.” Presbyterian Church of Sudan v. Talrs- man Energy, Inc., 244 F.Supp.2d 289, 311 (S.D.N.Y.2003). Accordingly, the ATCA may provide a basis for a concerted action claim of material
Page: HOUSE_OVERSIGHT_017892 →v. Robertson—Ceco Corp., 84 F.3d 560, 567 (2d Cir.1996); see also Terrorist Attacks I, 349 F.Supp.2d at 810-11 (reviewing due process requirements); Ungar v. Palestinian Auth., 153 F.Supp.2d 76, 87 (D.R.1.2001) (requiring minimum contacts with the United States for personal jurisdiction under *558 ATA).
Page: HOUSE_OVERSIGHT_017921 →a violation of international law, Kadic, 70 F.3d at 240, and the ATCA includes “actions premised on a theory of aiding and abetting and conspiracy.” Presbyterian Church of Sudan v. Talisman Energy, Inc., 244 F.Supp.2d 289, 311 (S.D.N.Y.2003). The ATCA, therefore, may provide a basis of recovery for those Plaintiffs who are al
Page: HOUSE_OVERSIGHT_017925 →Entities connected to both Presbyterian Church of Sudan and Ungar

U.S. Treasury
ORGANIZATION
United States
LOCATION
al-Qaeda
ORGANIZATION
Somalia
LOCATIONAshton
PERSON
Philadelphia
LOCATION
Arabia
LOCATION
Sudan
LOCATIONCasey
PERSON
Osama bin Laden
PERSON
New York
LOCATIONArndt
PERSON
Bill Clinton
PERSONSecond Circuit
ORGANIZATIONKadic
PERSON
Batterjee
PERSON
Khalifa
PERSON
Turki
PERSON
James P. Kreindler
PERSONBurnett
PERSON