Every indexed document

“Saudi American Bank knowingly provided material support and resources to al Qaida” by “finance [ing] many of the projects undertaken by Osama bin Laden and al Qaida in the Sudan during the years that the al Qaida leadership structure opera...

Al Rajhi Bank was warned by United States government officials “that their financial systems were being manipulated or utilized to fund terrorist organizations such as Al Qaeda.” SPA55 (Terrorist Attacks I); JA 2584-86; infra pp. 93-95. “De...

including by making direct donations to them

plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader contex...

111 it radically understated the scope and detail surrounding those direct allegations. Far from presenting bare conclusions

“Congress[] clearly expressed [an] intent to cut off the flow of money to terrorists at every point along the causal chain of violence.” Boim I

Heightened Standard In Evaluating Plaintiffs’ Pleadings.

the district court misapplied fundamental legal principles governing the assessment of a complaint and related pleadings upon a motion to dismiss. It also dramatically understated or disregarded the scope

an ATA claim may be predicated on the provision of support without plaintiffs having to establish that the defendants sought to advance any particular terrorist attack -- or even terrorist activities generally -- by the entities or persons....

broadly defined. Congress accomplished this purpose by “codify[ing] general common law tort principles and ... extend[ing] civil liability for acts of international terrorism to the full reaches of traditional tort law.” Boim v. Quranic Lit...

the district court declined to apply hornbook tort principles in concluding that defendants owed no “duty of care” to plaintiffs

and the district court acknowledged that recovery could be predicated on the provision of material support to a terrorist organization such as al-Qaeda when the supporter knows the nature of the recipient. The court concluded

and to have supported al-Qaeda through a variety of channels.101 Jameel’s sponsorship of al-Qaeda flowed largely through purported charities

by providing much of the funding al-Qaeda needed to sustain its global operations

the CRS report described the Golden Chain as:

such as the actual minutes of al Qaeda meetings

81 both of *52 whom have direct ties to bin Laden.82 Both bin Mahfouz and al Rajhi are identified as primary al-Qaeda sponsors on the “Golden Chain

and Tadamon’s other shareholders included al Qaeda material sponsors FIBS

the Sudanese regime that provided safehaven and support to bin Laden and al-Qaeda held a direct interest in Faisal Islamic Bank.77 Its founders included Yousef Nada

by also providing financial services to al-Qaeda charity fronts including the MWL