1 Cal. Civ. Proc. Code §354.4.

2 Movsesian v. Victoria Versicherung AG, 578 F.3d 1052 (9th Cir. Aug. 20, 2009).

3 Id. at 1055.

4 Similar California legislation extending the statute of limitations for other claims by Armenian victims’ heirs was held barred by a post–World War 1 claims settlement between the United States and Turkey. John, R. Crook, Contemporary Practice of the United States, 102 AJIL 349 (2008)Google Scholar.

5 578 F.3d at 1056.

6 539 U.S. 396 (2003).

7 578 F.3d. at 1056–57.

8 Id. at 1058.

9 Mat 1060.

10 Id. at 1061 (citation omitted).

11 Id. at 1063.

12 Fla. Stat. §§559.926–559.939.

13 ABC Charters v. Bronson, No. 08–21865–CIV–GOLD/MACILILEY (S.D. Fla. Apr. 14, 2009) (order granting motion for summary judgment), at http://www.flsd.uscourts.gov.

14 Carmen, Gentile, Travel Agents Booking Trips to Cuba Win Suit, N.Y. Times, Apr. 15, 2009 Google Scholar, at A16

15 As summarized in the White House Fact Sheet, Reaching Out to the Cuban People (Apr. 13, 2009)Google Scholar, at http://www.whitehouse.gov/the_press_office/Fact–Sheet–Reaching–out–to–the–Cuban–people/: [T]he President has directed the Secretaries of State, Treasury, and Commerce to take the needed steps to:

• •

  • Lift all restrictions on transactions related to the travel of family members to Cuba.

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  • Remove restrictions on remittances to family members in Cuba.

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  • Authorize U.S. telecommunications network providers to enter into agreements to establish fiber–optic cable and satellite telecommunications facilities linking the United States and Cuba.

• •

  • License U.S. telecommunications service providers to enter into roaming service agreements with Cuba’s telecommunications service providers.

• •

  • License U.S. satellite radio and satellite television service providers to engage in transactions necessary to provide services to customers in Cuba.

• •

  • License persons subject to U.S. jurisdiction to activate and pay U.S. and third–country service providers for telecommunications, satellite radio and satellite television services provided to individuals in Cuba.

• •

  • Authorize the donation of certain consumer telecommunication devices without a license.

• •

  • Add certain humanitarian items to the list of items eligible for export through licensing exceptions.

See Stolberg, Sheryl Gay & Damien, Cave, Obama Opens Door to Cuba, but Only a Crack, N.Y. Times, Apr. 13, 2009 Google Scholar, at A6; Stolberg, Sheryl Gay & Damien, Cave, Loosening Cuba Restrictions, Obama Leaves the Door Ajar for More, N.Y. Times, Apr. 14, 2009 Google Scholar, at A4; Karen, DeYoung, U.S. Lifts Almost All Curbs on Family Visits to Cuba, Wash. Post, Sept. 4, 2009 Google Scholar, at A10.

16 Statement of Interest of the United States, ABC Charters v. Bronson, at http://washingtonbureau.typepad.com/files/115–statement–of–interest–of–usa–3.20.09.pdf.

17 ABC Charters v. Bronson, mem. op. at 10.

18 Id.