On September 29, 2015, a U.S. District Court (Court) dismissed [3] Saudi Arabia as a defendant in In re Terrorist Attacks on September 11, 2001, a lawsuit brought by the families of victims of the attacks. The Court rejected the plaintiff’s allegations that Saudi Arabia and several charities under the Saudi High Commission for Relief of Bosnia & Herzegovina (SHC) had provided operational and financial support to al Qaeda in carrying out the attacks, noting that “Saudi Arabia, as a foreign state, and the SHC, as an instrumentality of Saudi Arabia, are immune from suit unless one of the FSIA's enumerated exceptions to immunity applies.” According to the Court, the “only potentially applicable exception to immunity is the noncommercial tort exception,” 28 U.S.C. § 1605(a)(5) [4], which covers only those torts that are committed entirely inside the United States.  In the present case, the Court found that the plaintiff’s allegations “predominantly concern torts committed abroad.” It also rejected the argument that charities had acted on behalf of Saudi Arabia, finding that “[p]laintiffs also fail to allege facts that sufficiently show that Saudi Arabia controlled the day-to-day operations of these charities [and] therefore fail to implicate Saudi Arabia under an alter-ego theory.” The Court also rejected the plaintiff’s averment of facts, stating it would be “futile, however, because the additional allegations do not strip Defendants of sovereign immunity” because like the complaint it “fails to satisfy the entire tort rule.”