Murphy v. Islamic Republic of Iran, 740 F. Supp. 2d 51, 72 (D.D.C. 2010) (finding terrorist organization liable under 28 U.S.C. § 1605A(c)); see also Mohamad Br. at 30-34. Finally, the legislative history of the TVPA reveals that Congress’s use of the term “individual” in the TVPA was only to “make crystal cle