The following excerpt is from Bennett v. Islamic Republic of Iran, 825 F.3d 949 (9th Cir. 2016):
Two Seventh Circuit cases support our conclusion in this regard. In Wyatt v. Syrian Arab Republic , 800 F.3d 331, 343 (7th Cir. 2015), cert. denied , U.S. , 136 S.Ct. 1721, 194 L.Ed.2d 812 (2016), the court held that the plaintiffs need not comply with 1608(e) when proceeding under 1610(g). The court noted that 1608(e)
[825 F.3d 961]
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