(1) Whether historical commingling of assets
suffices to establish that proceeds of seized property have a commercial nexus with the United States
under the expropriation exception to the Foreign
Sovereign Immunities Act.
(2) Whether a plaintiff must make out a valid
claim that an exception to the Foreign Sovereign Immunities Act applies at the pleading stage, rather
than merely raising a plausible inference.
(3) Whether a sovereign defendant bears the
burden of producing evidence to affirmatively
disprove that the proceeds of property taken in violation of international law have a commercial
nexus with the United States under the expropriation
exception to the Foreign Sovereign Immunities Act.

Whether historical commingling of assets suffices to establish that proceeds of seized property have a commercial nexus with the United States under the expropriation exception to the Foreign Sovereign Immunities Act