Maria Hartman, a U.S. investor, owns a toy assembly plant in the Kingdom of Fromage Vert. At a tennis match between a leading U.S. player and a star Fromagian, Maria irritates the king by cheering for the American. The next day, the king issues an edict taking Ms. Hartman’s plant for the kingdom. Ms. Hartman sues Fromage Vert in U.S. District Court for the Southern District of New York, where the kingdom’s airline owns an office. Would the U.S. court have jurisdiction in the absence of a treaty? Do you think the Fromagian taking of the toy assembly plant was a commercial activity? Was it an “act of state”?