ertson held them to an unnecessarily stringent theory of causation and submit that the D.C. Circuit's subsequent decision in Kilbunz v. Socialist People's Libyan Arab Jamahiriya, 376 F.3d 1123 (D.C.Cir.2004), effectively overrules the holding in Burnett IL See Kilburn, 376 F.3d at 1129 (evaluating a claim under § 1605(a)(7

r the Libyan state and has used the long-form name Libyan Republic, while the Gaddafi government's name for the Libyan state is the Great Socialist People's Libyan Arab Jamahiriya. Background 2011 uprising and civil war Main article: 2011 Libyan civil war After popular movements overturned the rulers of Tunisia and Egypt, i