In Owens v. BNP Paribas S.A., 235 F. Supp. 3d 85, 100 (D.D.C. 2017) (hereinafter Owens II), the court dismissed a lawsuit filed against an international bank by the victims and families affected by the 1998 U.S. embassy bombings. The dismissed complaint alleged that the bank was civilly liable for the victims’ injuries under the Anti-Terrorism Act (ATA). In dismissing this claim, the court addressed the ill-defined proximate causation requirement necessary to trigger liability under the ATA, as well as secondary liability under the ATA.
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