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Jam, et al. v. International Finance Corporation - Defendant International Finance Corporation's Memorandum of Law in Support of its Motion to Dismiss

Author: White & Case, counsel for International Finance Corporation, Published on: 1 July 2015

This case involves the alleged environmental impact of a power plant in Gujarat, India…The sole U.S. touch-point of this entire case is that one minority lender to the project company is an international organization, International Finance Corporation (“IFC”), which happens to be head-quartered in Washington, but with which Plaintiffs have no legal relationship. Given the identity of the parties and the locus of the claims, this Court should dismiss this action in its entirety with prejudice for the following reasons. First, IFC is entitled to absolute immunity under the International Organizations Immunities Act…Second, the complaint should be dismissed in its entirety on grounds of forum non conveniens…Third, Plaintiffs have failed to join at least three indispensable parties to this suit…

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