Full opinion text
Opinion and Order CASEY, District Judge. The Court presumes familiarity with the factual background giving rise to this mul-ti-district litigation. See In re Terrorist Attacks on September 11, 2001, 349 F.Supp.2d 765 (S.D.N.Y.2005) (“Terrorist Attacks I”). Generally, Plaintiffs are representatives, survivors, and insurance carriers of the victims of the attacks of September 11, 2001, who allege, pursuant to various theories of liability including the Antiterrorism Act (“ATA”), 18 U.S.C. § 2331 et seq.; the Alien Tort Claims Act (“ATCA”), 28 U.S.C. § 1350; the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961 et seq.; the Torture Victim Protection Act (“TVPA”), 28 U.S.C. § 1350 note; theories of aiding and abetting, civil conspiracy, intentional infliction of emotional distress, negligence, survival, wrongful death, trespass, and assault and battery, that Defendants are responsible for those attacks as terrorists, state sponsors of terror, or material sponsors of terror. In Terrorist Attacks I, the Court resolved several motions to dismiss the complaints by various Defendants. Additional motions remain pending before the Court. Saudi High Commission (“SHC”), HRH Prince Salman bin Abdulaziz Al-Saud (“Prince Salman”), and HRH Prince Naif bin Abdulaziz Al-Saud (“Prince Naif’) move to dismiss the complaints for lack of subject matter jurisdiction pursuant to the FSIA, lack of personal jurisdiction, and failure to state a claim for relief. Immediately prior to the Court’s scheduled oral argument on these motions, the Federal Plaintiffs moved to supplement the record against Prince Salman and Prince Naif. Defendants Rabita Trust, Wa‘el Jalai-dan, and International Islamic Relief Organization (“URO”) move to dismiss the complaints for lack of personal jurisdiction and failure to state a claim. Other Defendants move to dismiss the complaints for failure to state a claim. Tarik Hamdi and Abdulrahman Alamoudi move to dismiss the Burnett and Federal complaints. Success Foundation moves to dismiss the Burnett complaint. The Burnett Plaintiffs denominate certain Defendants as the “SAAR Network entities.” The SAAR Network entities, which include African Muslim Agency, Grove Corporate, Heritage Education Trust, International Institute of Islamic Thought (“HIT”), Mar-Jac Investments, Mar-Jac Poultry, Reston Investments, Safa Trust, and York Foundation, move to dismiss the Burnett complaint. HIT also moves to dismiss the Ashton complaint. In addition to its motion to dismiss Burnett, Mar-Jac Poultry moves to dismiss the Ashton and Federal complaints. The Federal Plaintiffs label certain individuals “SAAR Network executives.” These Defendants, including Taha Al-Awani, Muhammad Ashraf, M. Omar Ashraf, M. Yaqub Mirza, Iqbal Unus, and Jamal Barzinji, move to dismiss the Federal complaint. Finally, Defendant National Commercial Bank (“NCB”) moves for reconsideration of this Court’s denial without prejudice of its motions to dismiss the Ashton and Burnett complaints. The Court resolves all the aforementioned motions in this opinion. I. Subject Matter Jurisdiction Under the FSIA Pursuant to the FSIA, a foreign state and its instrumentalities are presumed immune from this Court’s jurisdiction unless one of the statute’s exceptions applies. Robinson v. Gov’t of Malaysia, 269 F.3d 133, 138 (2d Cir.2001). “In contrast to a Rule 12(b)(6) motion to dismiss for failure to state a claim, in a challenge to FSIA subject matter jurisdiction, the defendant must present a ‘prima facie case that it is a foreign sovereign.’ ” Virtual Countries v. Republic of South Africa, 300 F.3d 230, 241 (2d Cir.2002) (quoting Cargill Int’l S.A. v. M/T PAVEL DYBENKO, 991 F.2d 1012, 1016 (2d Cir.1993)). “Then, the plaintiff ‘has the burden of going forward with evidence showing that, under the exceptions to the FSIA, immunity should not be granted.’ ” Virtual Countries, 300 F.3d at 241 (quoting Cargill, 991 F.2d at 1016); see also Terrorist Attacks I, 349 F.Supp.2d at 792-797 (explaining that the possibly relevant exceptions to immunity in this litigation include the commercial activities, torts, and state sponsor of terrorism exceptions). Determining whether this burden is met involves a ‘review [of] the allegations in the complaint, the undisputed facts, if any, placed before [the court] by the parties, and — if the plaintiff comes forward with sufficient evidence to carry its burden of production on this issue^ — [resolution of] disputed issues of fact.’ ” Virtual Countries, 300 F.3d at 241 (quoting Robinson, 269 F.3d at 141). Throughout the inquiry, Defendants retain the burden of persuasion, which they must meet by a preponderance of the evidence. Virtual Countries, 300 F.3d at 241; see also Robinson, 269 F.3d at 141 n. 8. A. Allegations Against Defendants Asserting Foreign Sovereign Immunity 1. Saudi High Commission In 1993, then-King Fahad bin Abdulaziz Al-Saud, the President of the Council of Ministers of Saudi Arabia, decreed the formation of SHC, also known as the Saudi High Relief Commission, by High Order 17419. (Ashton Compl. ¶ 446; Burnett Compl. ¶ 392; Federal Compl. ¶ 180; see also SHC Mem. in Sup. Mot. to Dismiss at 3.) The same High Order named Defendant Prince Salman the President of SHC. (Ashton Compl. ¶ 446; Burnett Compl. ¶ 392; SHC Mem. in Sup. Mot. to Dismiss at 3.) SHC allegedly has contributed $600 million to aid “Bosnian Muslims impoverished by the country’s recent civil war.” (Ash-ton Compl. ¶ 446; Burnett Compl. ¶ 392.) Plaintiffs claim, however, that SHC does not provide support to the needy but actually diverts funds for terrorist activities. (Ashton Compl. ¶ 454; Burnett Compl. ¶ 404.) In support, Plaintiffs allege that Prince Salman received a letter in September 2000 from a Bosnian association claiming SHC did not provide charitable assistance, and that none of the money collected after the fall of Srebrenica in July 1995 actually reached the Srebrenican people. (Ashton Compl. ¶¶ 454-55; Burnett Compl. ¶¶ 404-05; Federal Compl. ¶¶ 185, 457.) Plaintiffs claim SHC’s financial records fail to account for $41 million. (Ash-ton Compl. ¶ 456; Burnett Compl. ¶ 407; Federal Compl. ¶ 460.) SHC allegedly made donations to charity Defendant Tai-bah and the bin Laden Establishment. (Ashton Compl. ¶¶ 376, 462 (relying on 1995 bin Laden interview); Burnett Compl. ¶ 298.) Plaintiffs also claim that SHC is responsible for “importing the extreme form of Saudi Islam, Wahhabism” to Bosnia. (Ashton Compl. ¶ 447; Burnett Compl. ¶ 393.) The Federal Plaintiffs allege that al Qaeda fighters began entering Bosnia-Herzegovina in 1992 disguised as SHC relief workers. (Federal Compl. ¶ 183.) On October 21, 2001, a group of Algerians who were supposedly part of the al Qaeda network were arrested in Bosnia Herzegovina on charges of terrorism directed at the United States embassy. (Ashton Compl. ¶¶ 448-49; Burnett Compl. ¶¶ 394-95.) One of the arrested, Sabir Lamar, apparently worked for SHC as an Arabic language teacher. (Ashton Compl. ¶ 450; Burnett Compl. ¶ 396.) Also in October 2001, Plaintiffs claim that United States forces raided the Sarajevo branch of SHC and “found computer hard drives with photographs of the World Trade Center before and after its collapse as well as photos of United States embassies in Kenya and Tanzania and the U.S.S. Cole.” (Ashton Compl. ¶ 451; Burnett Compl. ¶ 397; Federal Compl. ¶¶ 186, 458.) The U.S. forces also apparently found files on pesticides and crop dusters, the locations of Washington government buildings, fake State Department badges, and cash. (Ashton Compl. ¶¶ 451, 453; Burnett Compl. ¶¶ 397, 399; Federal Compl. ¶¶ 186, 459.) After the raid, the Financial Police of the Federation of Bosnia Herzegovina Ministry of Finance analyzed the seized documents and stated that some did “not belong in the scope of work of a humanitarian organization.” (Federal Compl. ¶¶ 187, 459; see also Ashton Compl. ¶ 452; Burnett Compl. ¶ 398.) The Federal Plaintiffs claim that the SHC “has long acted as a fully integrated component of al Qaida’s logistical and financial support infrastructure ... [and that the attacks of September 11 were] a direct, intended and foreseeable product of [its] participation in al Qaida’s jihadist campaign.” (Federal Compl. ¶¶ 182,189.) 2. Prince Salman Prince Salman is a member of the Kingdom of Saudi Arabia’s Council of Ministers, the governor of the province of Riyadh, and the President of Defendant SHC. (Prince Salman Mem. in Sup. Mot. to Dismiss at 2.) Plaintiffs allege that Prince Salman provided material support to Osama bin Laden and al Qaeda. (Ash-ton Compl. ¶ 255; Burnett Compl. ¶ 403; Federal Compl. ¶¶ 455, 463; see also Federal RICO Statement Applicable to Saudi Princes at Ex. A.) The Federal Plaintiffs claim Prince Salman “fully intended [SHC] would serve as a vehicle for funding and supporting Islamic militants in Bosnia, including elements of the al Qaida movement.” (Federal Compl. ¶ 456.) “Prince Salman knowingly failed to take appropriate actions regarding the management and use of funds of the SHC in Bosnia.” (Ash-ton Compl. ¶457; Burnett Compl. ¶406.) On December 30, 2000, the Embassy of the State of Palestine in Riyadh sent Prince Salman a letter expressing Yasser Arafat’s concern regarding the funding of radical organizations in Palestine. (Ashton Compl. ¶ 291; Burnett Compl. ¶ 402.) Further, Plaintiffs claim Prince Salman “has a history of funding Islamic extremism,” because he was named the Chairman of the General Donation Committee for Afghanistan in 1980, which gave $39 million to aid the Afghan mujahideen. (Ash-ton Compl. ¶ 289; Burnett Compl. ¶ 400.) In 1994, Prince Salman allegedly stated that he had personally raised more than six million Saudi Riyals for Defendant IIRO and Sanabel al-Kheer. (.Federal Compl. ¶ 462.) And in 1998, he allegedly donated one million Saudi Riyals during a fundraising drive by IIRO and Sanabel al-Kheer. (Federal Compl. ¶ 461.) In 1999, Prince Salman donated $400,000 during a fundraising event organized by charity Defendants IIRO, World Assembly of Muslim Youth (“WAMY”), and Al-Haramain Foundation for the benefit of Bosnia Herzegovina and Chechnya. (Ashton Compl. ¶ 290; Burnett Compl. ¶ 401; Federal Compl. ¶ 461.) Finally, Plaintiffs claim that members of the Saudi royal family have assets and do business in the United States. {Ashton Compl. ¶ 296.) 3. Prince Naif Prince Naif has been the Minister of Interior of the Kingdom of Saudi Arabia since 1975. (Ashton Compl. ¶ 286; Federal Compl. IT 433; Prince Naif Mem. in Supp. Mot. to Dismiss at 1, 5.) According to Plaintiffs, the Minister of Interior “controls the activities of Islamic Charities and is empowered to verify their legality and conduct.” {Ashton Compl. ¶286; Burnett Compl. ¶ 382; see also Federal Compl. ¶ 435 (alleging that as Minister of Interior Prince Naif is “responsible for the oversight of charities based within Saudi Arabia, including the operations of the Saudi Joint Relief Committee [ (‘SJRC’) ], Muslim World League [ (‘MWL’) ], IIRO, Saudi Red Crescent, WAMY, and al Haramain Foundation”).) He is also a member of the Council of Ministers and serves on the Supreme Council for Islamic Affairs. (Plaintiffs Mem. in Opp’n to Prince Naifs Mot. at 2-3, 5.) Plaintiffs claim that “Prince Naif has engaged in a pattern of conduct that aids, abets, and materially sponsors international terrorism and Al Qaeda.” (Ashton Compl. ¶¶ 288, 255; Burnett Compl. ¶¶ 342, 381; Federal Compl. ¶ 434; see also Federal RICO Statement Applicable to Saudi Princes at Ex. A.) They claim that along with other Saudi princes, Prince Naif made “monetary payoffs to Osama bin Laden’s al Qaeda.” (.Ashton Compl. ¶ 288; Burnett Compl. ¶ 381.) “In 1996, according to various intelligence sources, a group of Saudi princes ... met in Paris and agreed to continue contributing, sponsoring, aiding and abetting Osama bin Laden’s terrorist network.” (Burnett Compl. ¶ 347.) Plaintiffs claim that Prince Naif and the Saudi government received warnings from the United States and France that charitable donations to Islamic charities were being used to fund terrorism. (See Plaintiffs’ Mem. in Opp’n to Naifs Mot. to Dismiss at 5.) Prince Naif was present for one such meeting in 1994 with French Interior Minister Charles Pasqua. (Id.) The Federal Plaintiffs allege that Prince Naif has used his position as the Minister of Interior to “protect al Qai-da’s support infrastructure.” (Federal Compl. ¶ 438.) The Federal complaint further alleges that “[bjetween 1998 and 2000, the Kingdom of Saudi Arabia, through SJRC, diverted more than $74 million to al Qaida members and loyalists affiliated with SJRC bureaus. Throughout this time, [SJRC] was under the supervision and control of ... Prince Naif.” (Federal Compl. ¶¶ 126, 436.) “Prince Naif also heads the Saudi Committee for Relief to Afghans, ... [i]n this position, Prince Naif has channeled substantial financial and logistical support to sustain al Qaida’s presence and operations in Afghanistan.” (Id. ¶ 437.) Plaintiffs allege that Prince Naif is the “Chairman of the Saudi Arabian Committee for Support of the Intifada al Quds, [which] knowingly transferred large sums of money to the families of Hamas terrorists who had executed murderous attacks against Israelis.” (Ashton Compl. ¶ 287; Burnett Compl. ¶ 379; Federal Compl. ¶ 439; see also Burnett Compl. ¶ 380 (citing letter written on behalf of Yasser Arafat and claiming this committee funds radical groups).) As a result, Plaintiffs assert that “Prince Naif ... supports suicide martyrs.” (Ashton Compl. ¶ 287; Burnett Compl. ¶ 379.) The Federal Plaintiffs also allege that in 2003, U.S. Senator Charles Schumer asked that Prince Naif be replaced as Interior Minister because of his “well-documented history of supporting terrorist financing and ignoring the evidence when it comes to investigating terrorist attacks on Americans.” (Federal Compl. ¶ 441.) Finally, the Federal Plaintiffs claim Prince Naif made significant personal contributions to Saudi-based charities that were sponsors of al Qaida’s operations, including URO, MWL, WAMY, BIF, SHC, SJRC, and al Haramain. (Federal Compl. ¶¶ 442-43.) The Federal Plaintiffs seek leave to supplement the record against Prince Sal-man and Prince Naif with an article that appeared in Rus al Yusef an Egyptian publication, in August 1998. The unidentified author writes that Islamic aid organizations located in Afghanistan, Bosnia, Somalia, and Tajikistan provided funds and cover to terrorists. (See Federal Mot. to Supplement Record on Prince Naif and Prince Salman, Ex. 2, at 2.) Donors to these unidentified organizations “probably ha[d] no idea where their charity money ha[d] gone.” (Id.) Prince Naif reportedly responded that “if charity money is going to illegitimate targets, it must stop immediately.” (Id.) From this submission, the Plaintiffs argue that the Princes knew their charitable donations were going to terrorists. The submission is problematic for a variety of reasons and will not be accepted. First, Plaintiffs do not provide an explanation as why they were only able to obtain and translate the article on the eve of oral argument — well after the motions were fully submitted. Second, the article and its translation have not been authenticated. More pointedly, however, it simply does not say that the Princes were put on notice regarding specific charities and that they continued to contribute to those charities with the intent that their donations would assist al Qaeda. The Federal Plaintiffs’ motion to supplement the record against Prince Salman and Prince Naif is denied. B. Defendants’ Status as Foreign States for FSIA Purposes The FSIA provides the following definition of “foreign state”: (a) A “foreign state” ... includes a political subdivision of a foreign state or an agency or instrumentality of a foreign state as defined in subsection (b). (b) An “agency or instrumentality of a foreign state” means any entity — • (1) which is a separate legal person, corporate or otherwise, and (2) which is an organ of a foreign state or political subdivision thereof, or a majority of whose shares or other ownership interest is owned by a foreign state or political subdivision thereof, and (3) which is neither a citizen of a State of the United States ... nor created under the laws of any third country. 28 U.S.C. § 1603. Further, “immunity under the FSIA extends also to agents of a foreign state acting in their official capacities [because] [i]t is generally recognized that a suit against an individual acting in his official capacity is the practical equivalent of a suit against the sovereign directly.” Bryks v. Canadian Broad. Corp., 906 F.Supp. 204, 210 (S.D.N.Y.1995) (internal quotations omitted); see also Terrorist Attacks I, 349 F.Supp.2d at 788-89 (finding Princes Sultan and Turki were foreign states for FSIA purposes to the extent Plaintiffs alleged liability for actions taken in their official capacities). 1. SHC SHC contends that it is an organ, agency, or instrumentality of the Kingdom of Saudi Arabia and acts on behalf of the Kingdom to fund a range of humanitarian relief efforts to Bosnia, Egypt, and Somalia. (See generally Al-Roshood Deck, at Huffman Decl. Ex. A.) In support of its position as a foreign state, SHC submits the affidavits of Dr. Al-Nafissa, a Saudi Arabian lawyer and a Minister of State on the Council of Ministers in the Kingdom of Saudi Arabia, and Mr. Al-Roshood, who has been the Director of the Executive Office of SHC since its inception. The Court notes it is “required to give ‘great weight’ to any extrinsic submissions made by the foreign defendants regarding the scope of their official responsibilities.” Leutwyler v. Office of Her Majesty Queen Rania Al-Abdullah, 184 F.Supp.2d 277, 287 (S.D.N.Y.2001). King Faud authorized Dr. Al-Nafissa to make his declaration concerning SHC. (Al-Nafissa Deck ¶ 2, at Huffman Deck Ex. C.) Dr. Al-Nafissa attests that SHC is “an arm of the Saudi Arabian government [and that its actions] are in keeping with the foreign and domestic governmental policies of the Kingdom of Saudi Arabia.” (Id. ¶ 3.) SHC was formed by Decision of the President of the Council of Ministers in 1993. (Al-Roshood Deck ¶ 6.) In the same Decision, the Council of Ministers appointed Prince Salman as President of SHC. (Id. ¶ 7.) As President of SHC, Prince Salman is the head of SHC’s Executive Committee and Supreme Commission, members of which Prince Salman appoints. (Id.) SHC is staffed by civil servant employees of the Kingdom of Saudi Arabia. (Id. ¶ 10.) Dr. Al-Nafissa states that private charities in the Kingdom of Saudi Arabia receive governmental approval through Royal Order, are run by boards, and disburse funds in accordance with their charters. (AI-Nafissa Decl. ¶ 5.) In contrast, governmental commissions, such as SHC, are chaired by a governmental official, like Prince Salman, and conduct their affairs in accordance with the Kingdom’s policy objectives. (Id. ¶ 5.) According to Dr. Al-Nafissa, “[djecisions regarding causes to support and recipients for Saudi High Commission funds are within the discretion of the Executive Committee, the Supreme Commission, and Prince Salman.” (Id. ¶ 8.) The Kingdom of Saudi Arabia is SHC’s largest source of funding, having provided approximately 30% of the funds used and distributed by SHC. (AI-Roshood Decl. ¶ 24.) The remainder of SHC funds are collected through fundraisers “in accordance with the directives of ... King Fahd.” (Id. ¶ 5.) SHC can be sued for its administrative acts in the Board of Grievances. (Al-Nafissa Decl. ¶ 8.) In their complaint, the Federal Plaintiffs alleged that SHC is “an agency, instrumentality and organ of the Kingdom of Saudi Arabia.” (Federal Compl. ¶ 181.) They now back away from that allegation and join other Plaintiffs in disputing SHC’s status. Plaintiffs submit that SHC has repeatedly and systematically described itself as a non-governmental organization in representations to the Bosnian government. (See Plaintiffs’ Mem. in Opp’n to SHC Mot. to Dismiss at 10.) Thus, even if SHC is considered a foreign state, Plaintiffs assert it has implicitly waived its immunity through those representations. See 28 U.S.C. § 1605(a)(1) (FSIA waiver provision). Plaintiffs also argue that it is disingenuous for SHC to simultaneously maintain that it is an organ of the Kingdom and that this Court lacks personal jurisdiction over it when the Kingdom itself did not dispute the personal jurisdiction issue. In response to Plaintiffs’ arguments that it described itself as a non-governmental organization to Bosnian authorities, SHC submits the declaration of Hadsimuratovie Hajrudin, a Bosnian lawyer who serves as a legal advisor to SHC. (See generally Hajrudin Decl. at SHC Reply Ex. A.) Mr. Hajrudin states that SHC characterized itself as non-governmental in accordance with Article 22 of the Law on Humanitarian Activities and Humanitarian Organizations of the Federation of Bosnia and Herzegovina because SHC is “not considered part of the government of Bosnia-Herzegovina.” (Id. ¶ 4.) Mr. Hajrudin attests that the head of SHC’s European Office received diplomatic status in Bosnia-Herzegovina in 1996 because SHC is an organization of the Saudi government. (Id. ¶ 6.) He also states that the Kingdom of Saudi Arabia is represented by SHC when it makes donations to Bosnia-Herzegovina. (Id.) There is no dispute that SHC is a separate legal person from the Kingdom and not a citizen of the United States or any third country. See 28 U.S.C. § 1603. Accordingly, the only dispute regarding SHC’s status is whether it is an organ of the Kingdom. In Filler v. Hanvit Bank, 378 F.3d 213 (2d Cir.2004), the Second Circuit considered various factors to determine whether an entity could be considered an organ of a foreign sovereign. Id. at 217. The factors include: (1) whether the foreign state created the entity for a national purpose; (2) whether the foreign state actively supervises the entity; (3) whether the foreign state requires the hiring of public employees and pays their salaries; (4) whether the entity holds exclusive rights to some right in the [foreign] country; and (5) how the entity is treated under foreign state law. Id. at 217 (citations omitted). SHC offers undisputed evidence that it was created by the Kingdom’s Council of Ministers to “centralize all charitable giving from the Kingdom to Bosnia-Herzegovina [and that it was] vested with the sole authority to collect and distribute charitable funds in Bosnia.” (Al-Roshood Decl. ¶¶ 5-6; Hajrudin Decl. ¶ 6 & Ex. D (noting the Kingdom of Saudi Arabia provides humanitarian relief to Bosnia through SHC).) The Council of Ministers appointed Prince Salman to supervise SHC. (Al Roshood Decl. ¶¶ 7-9.) The salaries of SHC employees are paid by either the Kingdom of Saudi Arabia or out of the SHC budget. (Id. ¶ 10.) Like other Saudi Arabian government agencies, SHC can be sued in the administrative court of the Kingdom. (Al-Nafissa Decl. ¶ 8.) The Court finds that SHC has made a prima facie showing that it is a foreign sovereign. See Cargill, 991 F.2d at 1016 (requiring defendant to make prima facie case of sovereignty). Because SHC was formed by order of the Kingdom’s governing body, it provides the Kingdom’s aid to Bosnia, it is governed by a Saudi official and its employees are civil servants, it is an organ of the Kingdom of Saudi Arabia. See Filler, 378 F.3d at 217. Further, the Court finds SHC has not waived its sovereign immunity. The representations to the contrary on which Plaintiffs rely were made before this lawsuit was contemplated and cannot be read as a waiver of immunity from this court’s jurisdiction. The Second Circuit has made clear that the waiver of FSIA immunity must be explicit. See Banco de Seguros del Estado v. Mutual Marine Office, Inc., 344 F.3d 255, 261 (2d Cir.2003) (requiring wavier that unambiguously waives claims of immunity from legal proceedings in this country). Finally, Plaintiffs have not identified a factual dispute that would require jurisdictional discovery. See Filetech S.A. v. France Telecom S.A., 304 F.3d 180, 183 (2d Cir.2002) (finding no abuse of discretion where district court resolved jurisdictional issue without holding evidentiary hearing because factual disputes were “readily ascertainable” from the record). Accordingly, Plaintiffs must demonstrate that an exception under the FSIA applies to their claims against SHC. See Virtual Countries, 300 F.3d at 241. 2. Prince Salman and Prince Naif Aside from allegations regarding personal contributions to charities that were fronts for terrorists, the Plaintiffs’ claims against Prince Salman and Prince Naif concern their official functions. The allegations against Prince Salman, for example, center on his role as President of SHC, (see, e.g., Ashton Compl. ¶ 457; Burnett Compl. ¶ 406; Federal Compl. ¶ 456) or as Governor of Riyadh, (see Ashton Compl. ¶291; Burnett Compl. ¶402). Similarly, the allegations against Prince Naif center on his role as Minister of Interior of the Kingdom. (See Ashton Compl. ¶ 286; Burnett Compl. ¶ 382; Federal Compl. ¶ 435.) To the extent the allegations concern actions undertaken in their government positions, the Court finds that Prince Salman and Prince Naif are foreign states for FSIA purposes. See Leutwyler, 184 F.Supp.2d at 286-87 (recognizing that “individuals employed by a foreign state’s agencies or instrumentalities are deemed ‘foreign states’ when they are sued for actions undertaken within the scope of their official capacities”). Thus, Plaintiffs must also show that an FSIA exception applies to Princes Salman and Naif. Virtual Countries, 300 F.3d at 241. C. Application of FSIA Torts Exception Plaintiffs claim any immunity enjoyed by SHC, Prince Salman, and Prince Naif is overcome by the FSIA’s torts exception. The Federal Plaintiffs also argue that the commercial activities exception should lift the sovereigns’ immunity. For the reasons explained in its previous opinion, the Court concludes that the torts exception is the only exception relevant to the allegations contained in the Ashton, Burnett, and Federal complaints against SHC, Prince Salman, and Prince Naif. See Terrorist Attacks I, 349 F.Supp.2d at 793-94 (explaining that the Federal Plaintiffs’ reliance on the commercial activities exception is inappropriate because the alleged acts by Defendants were not the type of actions “by which a private party engages in trade and traffic or commerce,” and explaining the state sponsor of terrorism exception applies only to designated state sponsors of terror, of which the Kingdom of Saudi Arabia is not). The torts exception lifts immunity for “personal injury or death, or damage to or loss of property, occurring in the United States and caused by the tortious act or omission of that foreign state or any official ... of that foreign state while acting in the scope of his office.” 28 U.S.C. § 1605(a)(5). For jurisdiction to be proper under the torts exception, Plaintiffs will have to show, first, that the Defendants’ tortious acts caused Plaintiffs’ injuries. Robinson v. Gov’t of Malaysia, 269 F.3d 133, 142 (2d Cir.2001) (“If those activities could not render the Malaysian government liable for a tort under New York law, then it remained immune under § 1605(a)(5).”). Second, Plaintiffs must show that Defendants’ actions were not discretionary, i.e., not grounded in the social, economic, or political policies of the Kingdom of Saudi Arabia. Terrorist Attacks I, 349 F.Supp.2d at 794-97; see also 28 U.S.C. § 1605(a)(5)(A) (providing that the torts exception is not applicable to “any claim based upon the exercise or performance or the failure to exercise or perform a discretionary function regardless of whether the discretion be abused”). “Under the FSIA’s ‘discretionary function’ exception, ‘acts which are performed at the planning level of government, as opposed to those at the operational level, are protected by the immunity.’ ” Marchisella v. Gov’t of Japan, No. 02 Civ. 10023(DC), 2004 WL 307248, at *2 (S.D.N.Y. Feb.17, 2004) (quoting Napolitano v. Tishman Constr. Corp., No. 96 Civ. 4402(SJ), 1998 WL 102789, at *4 (E.D.N.Y. Feb.26, 1998)). Here, since SHC, Prince Salman, and Prince Naif are not alleged to have been the actual perpetrators of the attacks, Plaintiffs rely on theories of conspiracy and aiding and abetting. Conspiracy and aiding and abetting are varieties of concerted-action liability: conspiracy requires an agreement to commit a tortious act ..., aiding and abetting requires that the defendant have given substantial assistance or encouragement to the primary wrongdoer .... In order to be liable for acting in concert with the primary tortfeasor under either theory, the defendant must know the wrongful nature of the primary actor’s conduct. Pittman v. Grayson, 149 F.3d 111, 122-23 (2d Cir.1998). Accordingly, to survive these Rule 12(b)(1) motions to dismiss, Plaintiffs must plead facts from which it reasonably can be inferred that the Defendants knew or should have known that their tortious actions were supporting terrorists or terrorist fronts. Terrorist Attacks I, 349 F.Supp.2d at 800-01; see also Boim v. Quranic Literacy Inst., 291 F.3d 1000, 1023 (7th Cir.2002) (“Boim II”) (explaining elements of concerted-action civil liability under ATA); Virtual Countries, 300 F.3d at 241 (“Determining whether [Plaintiffs have demonstrated that one of the FSIA’s exceptions applies] involves a review of the allegations in the complaint, the undisputed facts, if any, placed before the court by the parties, and — if the plaintiff comes forward with sufficient evidence to carry its burden of production on this issue — resolution of disputed issues of fact.”) (internal quotations omitted). 1. SHC Even if Plaintiffs alleged that SHC was tortiously liable for the attacks of September 11, such allegations could not overcome the discretionary function exception. SHC offers undisputed evidence that all decisions regarding the distribution of humanitarian relief funds were within the sole discretion of its Chairman Prince Sal-man and the advisors he selected. (See Al-Nafíssa Deck ¶ 8.) Further, SHC was guided by the Kingdom’s policies regarding Bosnia-Herzegovina in making its funding determinations. (Id. ¶ 3.) Accordingly, SHC’s alleged misuse of funds and/or inadequate record-keeping — even if it resulted in the funds going to terrorists — was the result of a discretionary function and cannot be the basis for overcoming SHC’s immunity. See U.S. v. S.A. Empresa de Viacao Aerea Rio Grandense (Varig Airlines), 467 U.S. 797, 814, 104 S.Ct. 2755, 81 L.Ed.2d 660 (1984) (explaining FTCA discretionary function exception is designed to “prevent judicial ‘second-guessing’ of ... decisions grounded in social, economic, and political policy through the medium of an action in tort”); Marchisella, 2004 WL 307248, at *2 (explaining the FSIA’s discretionary function exception replicates that found in the FTCA and that courts rely on the FTCA for guidance in interpreting the scope of the FSIA’s exception); Kline v. Kaneko, 685 F.Supp. 386, 392 (S.D.N.Y.1988) (explaining sovereign’s decisions regarding formation and enforcement of national policies are discretionary functions); 28 U.S.C. § 1605(a)(5)(A) (stating torts exception is not applicable to claims based discretionary actions, even when that discretion is abused). Accordingly, the Court finds SHC is immune from suit in this litigation. Its motions to dismiss the Ashton, Burnett, and Federal complaints for lack subject matter jurisdiction are granted. 2. Prince Salman and Prince Naif Similarly, even if Plaintiffs adequately plead a tort against Prince Salman and Prince Naif, the discretionary function exception prevents this Court from exercising jurisdiction over them in their official capacities. Plaintiffs take issue with Prince Salman’s management of SHC and its funding decisions. Prince Salman’s direction of SHC, however, is discretionary. He was appointed President of SHC by King Fahd to carry out the Kingdom’s policy toward the refugees of the Bosnian war. (A-Roshood Decl. ¶ 6; A-Nafissa Deck ¶ 5.) Plaintiffs claim that as Chairman of the General Donation Committee for Aghanistan he assisted the Mghanistan mujahideen in the 1980s. To the extent Prince Salman held this position as a member of the Saudi government, this was also a policy decision made at the operational level of government. Plaintiffs claim Yasser Aafat complained to Prince Salman as Governor of Riyadh regarding Saudi funding of extremists in Palestine. Plaintiffs do not allege, however, what relation that complaint has to the al Qaeda terrorists or this litigation. They argue that Prince Salman, who did not attend the meeting with the former French Minister of Interior, should have known from Saudi officials who did meet with him that unnamed terrorists were receiving funding from largely unidentified Saudi charities. See Terrorist Attacks I, 349 F.Supp.2d at 799. The Saudi attendees’ decisions concerning with whom the French Minister’s warnings should be shared and what the Saudi response would be, are surely grounded in social, economic, and political policy, and are, therefore, not actionable under the FSIA. Varig Airlines, 467 U.S. at 814, 104 S.Ct. 2755. Similarly, the claims against Prince Naif stem from his discretionary functions. The Plaintiffs complain that Prince Naif, as Minister of Interior, ignored warnings in 1994 from French Interior Minister Charles Pasqua that Islamic charities were being used to fund terrorism. Additionally, Plaintiffs contend that he did not adequately supervise certain Saudi charities whose diverted funds allegedly landed in the coffers of al Qaeda and Hamas. Prince Naifs role on the Council of Ministers and as Minister of Interior makes it “nearly self-evident” that his official acts are “squarely covered by the ‘discretionary function’ language of [the FSIA].” Burnett II, 292 F.Supp.2d at 20. As the Minister of Interior, Prince Naif oversees matters relating to Saudi public security, civil defense, fire service, police, passports, special security, and investigative forces. The Council of Ministers, of which he is a member, oversees the implementation of internal, external, financial, economic, educational, defense policies, and general affairs of state for the Kingdom. Prince Naifs official responsibilities included managing Saudi relations with Osama bin Laden, see Prince Naif Mem. in Supp. Mot. to Dismiss at 2 (stating Prince Naif urged the Kingdom to strip bin Laden of his Saudi citizenship in 1994), and thus became a target of al Qaeda himself (see, e.g., Bierstein Aff. in Opp’n to Prince Sultan’s Mot. to Dismiss (fatwa issued by Osama bin Laden expressing extreme bitterness toward Saudi Royal family).) Therefore, Prince Naifs administration of his responsibilities was “clearly grounded in social, economic, and political policy.” Burnett II, 292 F.Supp.2d at 21 (citing Varig Airlines, 467 U.S. at 814, 104 S.Ct. 2755)). This Court lacks subject matter jurisdiction over Prince Salman and Prince Naif for their official acts. The FSIA does not immunize an official for his private tortious acts, however. See 28 U.S.C. § 1605(a)(5) (explaining torts exception is relevant to official’s official acts); Leutwyler, 184 F.Supp.2d at 286-87 (explaining officials are “deemed foreign states when they are sued for actions undertaken within the scope of their official capacities”). Accordingly, the Court will consider the appropriateness of exercising personal jurisdiction over Prince Salman and Prince Naif for their alleged personal acts below. II. Personal Jurisdiction To survive the motions to dismiss under Federal Rule of Civil Procedure 12(b)(2), Plaintiffs must make a prima facie showing that personal jurisdiction exists over each moving Defendant. PDK Labs, Inc. v. Friedlander, 103 F.3d 1105, 1108 (2d Cir.1997). The Court reviews the complaints and affidavits in a light most favorable to Plaintiffs, id., but it does not accept conclusory allegations or draw “argumentative inferences.” Mende v. Milestone Tech., Inc., 269 F.Supp.2d 246, 251 (S.D.N.Y.2003) (citing Robinson v. Overseas Military Sales Corp., 21 F.3d 502, 507 (2d Cir.1994)). Plaintiffs offer two bases for personal jurisdiction. First, New York’s long-arm statute, which the Court looks to in federal question cases in which no federal statute provides for national service of process or when the Court is sitting in diversity. PDK Labs, 103 F.3d at 1108; Bank Brussels Lambert v. Fiddler Gonzalez & Rodriguez, 305 F.3d 120, 124 (2d Cir.2002). New York’s long-arm statute, C.P.L.R. 302(a)(2), provides for personal jurisdiction over a person who, personally or through an agent, “commits a tortious act within the state.” Because a co-conspirator can be considered an agent, see Chrysler Capital Corp. v. Century Power Corp., 778 F.Supp. 1260, 1266 (S.D.N.Y.1991), Plaintiffs argue that Defendants are subject to personal jurisdiction here based on the acts of their co-conspirators, the al Qaeda terrorists. As this Court has previously explained, to establish personal jurisdiction on a conspiracy theory, Plaintiffs must make a prima facie showing of conspiracy and allege facts warranting an inference that the defendant was a member of the conspiracy. Terrorist Attacks I, 349 F.Supp.2d at 805. “To plead a valid cause of action for conspiracy ... a plaintiff must allege the primary tort and four elements: ‘(a) a corrupt agreement between two or more persons, (b) an overt act in furtherance of the agreement, (c) the parties’ intentional participation in the furtherance of a plan or purpose, and (d) the resulting damage or injury.’ ” Chrysler Capital Corp., 778 F.Supp. at 1267 (quoting Kashi v. Gratsos, 790 F.2d 1050, 1055 (2d Cir.1986)). Further, “[t]o warrant the inference that a defendant was a member of the conspiracy, Plaintiffs must show that ‘(a) the defendant had an awareness of the effects in New York of its activity; (b) the activity of the co-conspirators in New York was to the benefit of the out-of-state conspirators; and (c) the co-conspirators acting in New York acted ‘at the direction or under the control’ of or ‘at the request of or on behalf of the out-of-state defendant.” Terrorist Attacks I, 349 F.Supp.2d at 805 (quoting Chrysler Capital Corp., 778 F.Supp. at 1268-69). The Court must resolve the question of whether a conspiracy exists “based upon an independent examination of the factual allegations while mindful of its duty to draw all factual inferences in plaintiffs’ favor.” Daventree v. Republic of Azerbaijan, 349 F.Supp.2d 736, 760 (S.D.N.Y.2004). The alternative basis for personal jurisdiction offered by Plaintiffs is found in Federal Rule of Civil Procedure 4(k). Rule 4(k)(l) provides that service of process establishes personal jurisdiction when service is authorized by a federal statute. Here, the ATA provides for personal jurisdiction through its nationwide service of process provision. See 18 U.S.C. § 2334(a); Fed.R.Civ.P. 4(k)(l)(D). In situations in which Defendants were not served in the United States pursuant to the ATA, Rule 4(k)(2) acts as a personal jurisdiction gap-filler “in the enforcement of federal law.” Fed.R.Civ.P. 4(k)(2) advisory committee’s note. For the Court to exercise personal jurisdiction pursuant to Rule 4(k)(2), “there must be a federal claim, personal jurisdiction must not exist over the defendant in New York or any other state, and the defendant must have sufficient minimum contacts with the United States as a whole such that the exercise of jurisdiction does not violate Fifth Amendment due process.” Terrorist Attacks I, 349 F.Supp.2d at 807 (citing United States v. Int’l Bhd. of Teamsters, 945 F.Supp. 609, 617 (S.D.N.Y.1996)). Under either basis offered by Plaintiffs, the exercise of personal jurisdiction must comport with due process requirements — there must be minimum contacts and the exercise of jurisdiction must be reasonable. Metro. Life Ins. Co. v. Robertson-Ceco Corp., 84 F.3d 560, 567 (2d Cir.1996); see also Terrorist Attacks I, 349 F.Supp.2d at 810-11 (reviewing due process requirements); Ungar v. Palestinian Auth., 153 F.Supp.2d 76, 87 (D.R.I.2001) (requiring minimum contacts with the United States for personal jurisdiction under ATA). If personal jurisdiction is based on New York’s long-arm statute, the Fourteenth Amendment’s due process standards apply. If jurisdiction is based on Rule 4(k), the Fifth Amendment applies. The analysis is essentially the same. “The principal difference is that under the Fifth Amendment the court can consider the defendant’s contacts throughout the United States, while under the Fourteenth Amendment only contacts with the forum state may be considered.” Chew v. Dietrich, 143 F.3d 24, 28 n. 4 (2d Cir.1998). Plaintiffs claim that Rule 4(k)’s minimum contacts requirement is satisfied because the Defendants have purposefully directed their activities at the United States. See Terrorist Attacks I., 349 F.Supp.2d at 807 (reviewing the purposefully directed activities theory). This Court has held that to succeed on this theory, “Plaintiffs must make a prima facie showing of each Defendant’s personal or direct participation in the conduct giving rise to Plaintiffs’ injuries.” Id. at 809. The Court does not require direct participation in the attacks themselves, but at least participation in al Qaeda’s terrorist agenda. In analyzing a defendant’s minimum contacts, courts distinguish between specific and general jurisdiction. “Specific jurisdiction exists when the forum exercises jurisdiction over the defendant in a suit arising out of the defendant’s contacts with that forum.” Terrorist Attacks I, 349 F.Supp.2d at 811 (citing Metro. Life Ins. 84 F.3d at 567-68). General jurisdiction is based on a defendant’s general business contacts with the forum. Because the defendant’s contacts are not related to the suit, a considerably higher level of contacts is generally required and the plaintiff must demonstrate the defendant’s continuous and systematic general business contacts with the forum. Metro. Life. Ins., 84 F.3d at 568; see also Helicopteros Nacionales de Colombia, S.A., 466 U.S. 408, 414-16, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984). In most instances, Plaintiffs do not specify which basis for personal jurisdiction applies to each Defendant, or whether the Defendant was served in the United States pursuant to the ATA’s nationwide service of process provision. Accordingly, in analyzing Defendants’ motions, the Court considers as a threshold matter whether Plaintiffs have made a prima facie showing of the Defendant’s minimum contacts with the United States as a whole. A. Prince Salman and Prince Naif Plaintiffs seek to hold Prince Salman responsible for the attacks of September 11, theorizing that Prince Salman purposefully directed his activities at the United States by contributing to and raising funds for URO, Sanabel-al Kheer, WAMY, and Al-Haramain. As for other contacts with the United States, Prince Salman owns stock in two United States corporations based in Texas, and, during a trip to the United States in 1989, he met with President George H.W. Bush and the governor of Maryland. (Plaintiffs’ Opp’n to Prince Salman Mot. to Dismiss at 21-22; see generally Parrett Aff.) Additionally, Plaintiffs claim that Prince Salman’s son attended school in California, had a residence in the United States, owned a corporation that breeds race horses in the United States, and is involved, through his estate, in a New Jersey lawsuit with a former employee. Id. They seek jurisdictional discovery to determine if Prince Salman has other contacts here. Plaintiffs do not allege that Prince Naif has any general contacts with the United States. Rather, they claim that he purposefully directed his activities toward the United States by making personal contributions to several Saudi-based charities. (Federal Compl. ¶¶ 442-43.) Plaintiffs must make a prima facie showing that Prince Salman and Prince Naif have minimum contacts with the United States. The minimum contacts requirement is satisfied “if the defendant has ‘purposefully directed’ his activities at the residents of the forum.” Burger King v. Rudzewicz, 471 U.S. 462, 474, 105 S.Ct. 2174, 85 L.Ed.2d 528 (1985). Foreseeability is not enough, there must be “some act by which the defendant purposefully avails itself of the privilege of conducting activities within the forum.” Id. Donating money to established humanitarian organizations that may or may not have been diverting funds to support al Qaeda cannot be considered primary participation in intentional wrongdoing expressly aimed at the United States. Terrorist Attacks I, 349 F.Supp.2d at 809 (citing In re Magnetic Audiotape Antitrust Litig., 334 F.3d 204, 208 (2d Cir.2003)). As to Prince Salman’s various limited contacts with the United States, they do not support general jurisdiction over him. The 1989 visit to the White House and Maryland is too far removed in time from the 2001 attacks. See, e.g., Metro. Life Ins. Co., 84 F.3d at 569 (explaining that a defendant’s “continuous and systematic” contacts with a forum must be examined over a period of time and finding a six-year period reasonable). Prince Salman’s deceased son’s contacts with the United States are irrelevant to this Court’s analysis. Keeton v. Hustler Magazine, Inc., 465 U.S. 770, 781 n. 13, 104 S.Ct. 1473, 79 L.Ed.2d 790 (“Each defendant’s contacts with the forum State must be assessed individually.”). Prince Salman’s ownership of shares in Texas corporations, on its own, cannot be considered sufficiently systematic and continuous to establish general jurisdiction. Helicopteros, 466 U.S. at 414-16, 104 S.Ct. 1868 (finding CEO’s travel to forum for contract negotiations, employees’ travel to forum for training, receipt of funds drawn on forum bank accounts, and purchase from forum companies were not contacts sufficiently systematic and continuous to establish general jurisdiction). Plaintiffs have not presented a genuine issue of jurisdictional fact such that discovery is necessary. Daventree, 349 F.Supp.2d at 761. Plaintiffs have not satisfied the constitutional requirement of showing that the Princes have minimum contacts with the United States. Accordingly, Prince Salman’s and Prince Naif’s motions to dismiss the Ashton, Burnett, and Federal complaints for lack of personal jurisdiction are granted. ' B. Rabita Trust Plaintiffs allege that Rabita Trust is a charitable organization which was created to organize the repatriation and rehabilitation of stranded Pakistanis from Bangladesh. Founded in 1988, the trust fund was started jointly by the government of Pakistan and the Saudi-based charity, [Defendant MWL], Rabi-ta Trust received the majority of its funding from the MWL and the Saudis, and [has] been involved with terrorism. (Ashton Compl. ¶ 521; Burnett Compl. ¶ 268.) The charity initially received funding from its founders to help relocate 250,-000 displaced refugees. (.Ashton Compl. ¶ 522; Burnett Compl. ¶ 269.) Plaintiffs assert that Rabita Trust has actually relocated only a few hundred refugees. (Ash-ton Compl. ¶ 522; Burnett Compl. ¶ 269.) On October 12, 2001, the United States Treasury Department designated Rabita Trust a Specially Designated Global Terrorist Entity and froze its assets. (Ash-ton Compl. ¶ 312, 527; Burnett Compl. ¶ 236; Federal Compl. ¶¶ 117, 214.) Rabi-ta Trust is allegedly related to various other charity Defendants and al Qaeda. For instance, as a subsidiary of MWL, it is a “sibling organization of the IIRO.” (Ash-ton Compl. ¶ 525; Burnett Compl. ¶ 272; Federal Compl. ¶ 113.) Through MWL and its own officers, Rabita Trust is also related to the SAAR Network. (Ashton Compl. ¶¶ 338, 526-28; Burnett Compl. ¶¶ 273-75; Federal Compl. ¶ 213.) Plaintiffs claim that “Rabita Trust is an al Qaeda front” and that its General Director, Wa'el Julaidan, is a known al Qaeda member. (Ashton Compl. ¶ 523; Burnett Compl. ¶ 270; Federal Compl. ¶¶ 100, 121, 210.) In a list of orders obtained in a raid of BIF’s Sarajevo’s offices, investigators allegedly recovered a document from Osa-ma bin Laden regarding the management of Islamic charities in which he urged the creation of a committee to receive and distribute donations to al Qaeda and suggests Rabita Trust’s participation. {Federal Compl. ¶¶ 195, 211.) Rabita Trust claims that it does not have an office in the United States and that the complaints are devoid of any allegations that it directed money to terrorists. It admits that it has been designated a terrorist, but claims it does not have the same connections to the United States, bin Laden, and al Qaeda that Defendants Benevolence International Foundation (“BIF”) and Adel A.J. Batterjee had. See Terrorist Attacks I, 349 F.Supp.2d at 823-25 (finding Court had personal jurisdiction over Mr. Batterjee based on his designation as a global terrorist, his role with BIF, another designated terrorist, his leadership of BIF’s United States operations, and his relationship with Osama bin Laden). It also argues that the document that Plaintiffs attribute to Osama bin Laden is similar to the Golden Chain, in that it lacks foundation and authentification. See Terrorist Attacks I., 349 F.Supp.2d at 817 (“The ‘Golden Chain’ is a group of documents that was discovered by Bosnian authorities searching the offices of charity Defendant BIF in March 2002. Plaintiffs claim the ‘Golden Chain’ contains a list of early direct donors to al Qaeda.”) In assessing whether Rabita Trust has purposefully directed its activities at the United States under Rule 4(k), the Court is mindful of the executive branch’s designation of it as a SDGT. While the designation is not dispositive on its own, it does warrant some deference. In the realm of foreign affairs, the executive branch has access to “confidential sources of information [and] agents in the form of diplomatic, consular and other officials.” United States v. Curtiss-Wright Corp., 299 U.S. 304, 320, 57 S.Ct. 216, 81 L.Ed. 255 (1936). Entities are designated under Executive Order 13224 if the executive branch determines they are involved in terrorist activities. See Executive Order 13224 Fact Sheet. Courts enjoy great discretion in deciding whether to order jurisdictional discovery before resolving motions to dismiss for lack of personal jurisdiction. See, e.g., APWU v. Potter, 343 F.3d 619, 627 (2d Cir.2003). This Court finds that such discovery would be helpful in assessing whether any of Rabita Trust’s activities were directed at the United States. Accordingly, Rabita Trust’s motions to dismiss the Ashton, Burnett, and Federal complaints are denied without prejudice. C. Wa‘el Jalaidan The United States Department of Treasury has designated Defendant Jalaidan a terrorist, frozen his assets, and named him “one of the founders of al Qaeda.” (Ashton Compl. ¶ 304; Burnett Compl. ¶ 255; Federal Compl. ¶¶ 117, 91.) The Treasury Department “characterized [him] as having ‘directed organizations that have provided financial and logistical support to al-Qa-ida, [he] is the logistics chief of bin Laden’s organization and fought on bin Laden’s side in Afghanistan.’ ” (Ashton Compl. ¶¶ 304, 312, 523-24; Burnett Compl. ¶¶ 236, 255, 271; Federal Compl. ¶ 117; see also Federal Compl. ¶ 196 (claiming documents found in the Bosnian raid of BIF offices contained a note from Osama bin Laden to Jalaidan regarding al Qaeda’s need for weapons).) Further, Osama bin Laden and his lieutenant, Abu Zubaydah, allegedly “have acknowledged Wa'el Julaidan as a known associate of their operations. Julaidan has been the head of various non-government organizations providing financial and logistical support to the al-Qa‘ida network.” CAshton Compl. ¶¶ 304, 312, 341, 484; Burnett Compl. ¶ 236, 255.) Jalaidan was in charge of the MWL in Peshawar, Pakistan and served as the General Director of Rabita Trust. (Ash-ton Compl. ¶ 304; Burnett Compl. ¶ 236, 255.) He “operated MWL offices that served in the early days of al Qaeda to attract and train holy warriors from around the world for the war in Afghanistan” and has “repeatedly aided and abetted terrorists.” (Ashton Compl. ¶¶ 304, 312; Burnett Compl. ¶255.) Jalaidan is also allegedly connected to Defendant SJRC. (Ashton Compl. ¶ 484; Federal Compl. ¶ 125.) Defendant Jalaidan argues that the allegations against him are simply allegations of guilt by association, and do not include any specificity regarding dates to put his actions in context. He urges the Court to not rely on his designation as a terrorist by the Treasury Department because he did not have an opportunity to rebut it. Plaintiffs do not claim to have served Mr. Jalaidan in the United States under the ATA’s nationwide service provision. Accordingly, Rule 4(k)(2) may provide a basis for personal jurisdiction. There are several federal claims at issue in this litigation and Plaintiffs have not made a pri-ma facie showing that Mr. Jalaidan is subject to personal jurisdiction in New York or any other state. The Court turns to Mr. Jalaidan’s contacts with the United States. In addition to being designated as a global terrorist by the Department of Treasury, Mr. Jalaidan is alleged to be a founder and the logistical chief of al Qaeda, and affiliated with several other charities that are allegedly in al Qaeda’s fundraising network. In light of al Qaeda’s public declarations of war against the United States, someone who is alleged to be a founder, an admitted associate, and a provider of financial and logistical support to al Qaeda, has purposefully directed his activities at the United States such that the exercise of personal jurisdiction over him is reasonable. See Mwani v. bin Laden, 417 F.3d 1, 14 (C.A.D.C. 2005). D. IIRO Plaintiffs claim that IIRO has “materially supported terror around the globe, including Osama bin Laden and al Qaeda.” (Ashton Compl. ¶ 310; Burnett Compl. ¶¶ 234, 239; Federal Compl. ¶ 133.) In the early 1990s, IIRO “was rapidly becoming al Qaeda’s foremost charity used as a means to transfer funds, personnel, and other means of material support.” {Burnett Compl. ¶ 326; Federal Compl. ¶ 142.) Plaintiffs claim IIRO remains “firmly entrenched with Osama bin Laden’s al Qaeda organization” because of its support of an al Qaeda guest house in Egypt, its office’s close proximity to Osama bin Laden’s personal office in Sudan, and its relationship with bin Laden’s brother-in-law Defendant Mohammed Jamal Khalifa. (Ashton Compl. ¶¶ 310, 315, 317; Burnett Compl. ¶¶ 234, 239, 241.) Mohammed Jamal Khalifa headed IIRO’s Philippines office, which served as a center of terrorist financing and training. (Ashton Compl. ¶ 310; Burnett Compl. ¶ 234; Federal Compl. ¶¶ 135-36.) Khalifa collected and laundered money for al Qae-da through IIRO’s Phillipines office. (Ashton Compl. ¶ 316; Burnett Compl. ¶ 240.) Through Khalifa, IIRO was allegedly involved with bombings in Jordan in 1993 and 1994, the 1993 attack on the World Trade Center, plots to assassinate former President Bill Clinton and the late Pope John Paul II and to simultaneously blow up twelve American airliners, and the 1998 Embassy bombings in Africa. (Ashton Compl. ¶¶ 310, 318, 510-12; Burnett Compl. ¶¶ 189, 234, 239 240, 242; Federal Compl. ¶¶ 136,137,139.) Plaintiffs claim IIRO supported al Qae-da terrorists in other ways as well. One of the September 11 hijackers claimed to be working for IIRO’s Fazeh Ahed. (Ashton Compl. ¶ 322; Burnett Compl. ¶ 246.) IIRO allegedly funded the Taliban regime with $60,000,000. (Ashton Compl. ¶ 322; Burnett Compl. ¶ 246.) Pakistan deported 89 aid workers from the IIRO on the grounds that they were supporting al Qae-da. (Ashton Compl. ¶ 322; Burnett Compl. ¶ 246; Federal Compl. ¶ 144.) Plaintiffs claim IIRO funded al Qaeda training camps in Afghanistan. (Ashton Compl. ¶ 556; Federal Compl. ¶ 134 (basing allegations on declassified 1996 CIA report alleging IIRO funded six al Qaeda training camps, including those from which it planned, approved, and coordinated the September 11 attacks and where hijackers received training and indoctrination).) IIRO funded Egyptian al-Jihad, a branch of al Qaeda. (Burnett Compl. ¶ 243.) IIRO conducted a joint fundraising event with al-Haramain and WAMY in Riyadh, Saudi Arabia in December 1999. (Burnett Compl. ¶ 156.) Defendant MWL is the parent organization of IIRO and uses it as an “operational arm to perform many of its charitable activities.” (Ashton Compl. ¶ 298; Federal Compl. ¶¶ 130-31.) Plaintiffs claim IIRO also works with numerous other charities allegedly affiliated with al Qaeda, including SJRC, BIF, Global Relief Foundation, Tai-bah International, Islamic African Relief Agency, and WAMY. (Ashton Compl. ¶ 320; Burnett Compl. ¶¶ 172, 244; Federal Compl. ¶ 147.) The FBI raided IIRO’s offices in Virginia after September 11, 2001. (Ashton Compl. ¶ 322; Burnett Compl. ¶ 246.) Plaintiffs allege that IIRO operates under the name International Relief Organization (“IRO”) in the United States in Falls Church, Virginia, and that the IIRO and IRO transfer money to each other and have the same president. (Ashton Compl. ¶¶ 311, 320; Burnett Compl. ¶¶ 172, 235, 237; Federal Compl. ¶ 146 (U.S. branch established in 1991); see also Parrett Aff. Ex. 1 (attaching IRO’s 1991 certificate of incorporation in Virginia); id. Ex. 2 (attaching IRO’s 1993 certificate for doing business in Virginia under assumed name of International Islamic Relief Organization (IIRO)).) IIRO claims IRO was finally dissolved as a corporate entity in December 2002. (Saleh bin Abdallah Alsaikhan Decl. ¶ 10.) The parties agree that this Court’s exercise of personal jurisdiction over IIRO depends on its contacts with the United States as a whole under Rule 4(k)(l). The Court looks, therefore, at IIRO’s contacts with the United States. It appears that IIRO was operating in the United States until December 2002. It is alleged to have supported an al Qaeda guest house. Through its relationship with Mohammed Jamal Khalifa, it has allegedly been involved in several al Qaeda attacks and plots for other attacks. It has allegedly funded the Taliban and al Qaeda training camps in Afghanistan. The Court finds that Plaintiffs have made a prima facie case that IIRO has purposefully directed its activities at the United States, thus satisfying the constitutional minimum contacts requirement. IIRO’s motions to dismiss the Ashton, Burnett, and Federal complaints are denied. III. Failure to State a Claim In these Rule 12(b)(6) motions to dismiss for failure to state a claim, the Court accepts as true the facts alleged in the complaints and draws all reasonable inferences in favor of Plaintiffs. Harris v. City of New York, 186 F.3d 243, 247 (2d Cir.1999). The complaints should be dismissed only if it appears beyond doubt that Plaintiffs can prove no set of facts in support of their claims that would entitle them to relief. Id.; see also Hishon v. King & Spalding, 467 U.S. 69, 73, 104 S.Ct. 2229, 81 L.Ed.2d 59 (1984) (“A court may dismiss a complaint only if it is clear that no relief could be granted under any set of facts that could be proved consistent with the allegations.”). Federal Rule of Civil Procedure 8(a)(2) requires “a short and plain statement of the claim showing that the pleader is entitled to relief.” “This simplified notice pleading standard relies on liberal discovery rules and summary judgment motions to define disputed facts and issues and to dispose of unmeritorious claims.” Swierkiewicz v. Sorema, N.A., 534 U.S. 506, 512, 122 S.Ct. 992, 152 L.Ed.2d 1 (2002) (citing Conley v. Gibson, 355 U.S. 41, 47, 78 S.Ct. 99, 2 L.Ed.2d 80 (1957), Leatherma