13. Should a “stateless” person meaning an individual who is not a citizen of any country be eligible to invoke alienage jurisdiction? In BLAIRHOLDINGS CORP. v.

RUBINSTEIN, 133 F.Supp. 496 (S.D.N.Y.1955), defendant,278Serge Rubinstein, held a

“Nansen” passport issued after World War I by the League of Nations to stateless persons and had registered as a stateless person with the United States Department of Justice. In addition, the complaint described defendant as “not [being] a citizen of the United States.” Id.

at 498. The court held that there was no jurisdiction under 28 U.S.C. § 1332(a)(2) because plaintiff failed to show he was a citizen of a foreign state. Should it be of concern that a stateless party may be vulnerable to discrimination because no foreign state will voice offense from the party’s treatment in a state court? See Chemerinsky, Federal Jurisdiction § 5.3 (6th ed. 2012). Relatedly, should companies that are incorporated in nations that are not recognized by the United States be treated as stateless for purposes of alienage jurisdiction?