1. This case raises an important, circuit-splitting issue under the Foreign Sovereign Immunities Act, 28 U.S.C. § 1602 et seg. ("FSIA"): Whether the exercise of personal jurisdiction over a foreign state under the FSIA requires satisfaction of the minimum-contacts test. The Ninth Circuit's answer to this question is at odds with the plain language of the FSIA. Its holding openly conflicts with the four other circuits to have addressed this question and creates unnecessary hurdles for plaintiffs seeking to assert their rights against foreign states and their agents.

2. Under the FSIA, "[p]ersonal jurisdiction over a foreign state shall exist as to every claim for relief over which the district courts have jurisdiction *** where service has been made under section 1608 of this title." 28 U.S.C. § 1330(b).

Whether the Foreign Sovereign Immunities Act requires satisfaction of the minimum-contacts test for personal jurisdiction over a foreign state