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[PDF] Isa Saharkhiz, et al., v. Nokia Corporation, et al. - Memorandum of Law in Support of Defendant's Motion to Dismiss [US]

Plaintiffs’ claims...under the Alien Tort Statute...fail [because]...[a]s the Second Circuit reasoned in a decision issued last week, there is no specific, universal, and obligatory norm of international law that would support imposition of liability on corporate defendants...Plaintiffs’ claims...under the Torture Victims Protection Act...fail because TVPA liability is unavailable against corporations and cannot be imposed vicariously...Virginia law does not apply to alleged torts committed in Iran by Iranian government officials against Iranian citizens...Finally, because the Complaint pleads no facts suggesting conduct directed at or direct injury to Plaintiff Mehdi Saharkhiz, his claims must also be dismissed in their entirety. [refers to Nokia, Telecommunications Company of Iran (TCI), Islamic Republic News Agency]