On August 8, 2019, the United States Court of Appeals for the Ninth Circuit issued an opinion in the Bakalian v. Central Bank of Republic of Turkey [3] case, Case No. 13-55664. In this case, the Ninth Circuit affirmed the district court’s dismissal of plaintiffs’ claims seeking compensation from the Republic of Turkey and two Turkish national banks for lands that they claim were unlawfully confiscated from their ancestors during what the Court refers to as the Armenian Genocide of 1915–1923. In 2006, California adopted a statute extending the statute of limitations for claims arising out of the Armenian Genocide to December 31, 2016. Thus, the claims filed by the plaintiffs in 2010 were not time-barred under the statute; however, the panel found that since the Court had previously found the statute to be unconstitutional, no statute existed to extend the statute of limitations and therefore the claims were time-barred. The panel held that since the claims were plainly time-barred, the Court need not address legal questions posed regarding Foreign Sovereign Immunities Act jurisdiction.