I. Whether the commercial activity exception to
the Foreign Sovereign Immunities Act, 28 U.S.C.
§ 1605(a)(2), applies to an otherwise immuneforeign government instrumentality, whenalleged acts involve breach of contract andparticipation with a foreign ruler's fraudulentsmear scheme, firing, and retaliation against aU.S. citizen employed by the instrumentality?

II. Whether federal common law immunizes a
foreign ruler alleged to have organized afraudulent smear report by New Yorkconsultants against a U.S. citizen?

III. Whether leave to amend the complaint should
have been granted under Fed. R. Civ. P.15(a)(2)?

Whether the commercial activity exception to the Foreign Sovereign Immunities Act applies to a foreign government instrumentality's alleged breach of contract and participation in a fraudulent smear scheme against a U.S. citizen employee