5. C. Defendants’ Status as States for FSIA Purposes The Court must first determine if the moving Defendants are “foreign states” for Foreign 22. Zakat is required almsgiving by all Mus- lims. See, e.g., Burnett Complaint at 275; id. 140. HOUSE_OVERSIGHT_017852 --- PAGE BREAK --- 788 purposes of

F.3d at 1023; Bown ITT, 340 F.Supp.2d at 906. Even move and launder money. 12(e) Statement {1 1. Plaintiffs allege that al Qaeda has pervert- ed the Zakat and Hararm principles in Islam- ic banking to collect and distribute money to individuals and cells throughout the world. Id. 494-9; see also Burnett

ionally allege that “DMI [Trust] and its affiliated and subsidiary companies have known that many of the ostensible charities to which they channeled Zakat and Haraam funds were, in fact, fronts for al Qaeda [, including ITRO and MWL].” *88 JA4337. “Despite the actual knowledge that money contributed to