the law and policy of the United States.”); Universal Trading & Inv. Co. v. Kiritchenko, No. C-99-3073, 2007 WL 2669841, at *8 (N.D.Cal. Sept. 7, 2007) (“The act of state doctrine ordinarily does not preclude judicial review of the extraterritorial effects of acts of state.”). Federal courts considering the extraterritorial effect of foreign state actions involving property have generally looked to the situs of the property in question. See, e.g., Trinh v. Citibank, N.A., 850 F.2d 1164, 1172 (6th Cir.1988) (“Generally speaking, an act of state will go unquestioned in United States courts only to the extent that it affects property whose ‘situs’ is within the territorial jurisdiction of the acting state.”); Drexel Burnham, Lambert Group Inc. v. Galadari, 777 F.2d 877, 881 (2nd Cir.1985) (<HOLDING>); Allied Bank, Int'l, 757 F.2d at 521-22
holding that when the basis of the earlier suit was that the plaintiff had had defaulted on a promissory note and the claim in the instant action is whether that promissory note was valid the transaction test is met holding that the situs of debt  for purposes of the act of state doctrine  was not in dubai when the terms of the relevant promissory note provided that the note was payable in united states dollars at the place of the holders designation holding that standing at inception of the suit was not established where the note attached to the complaint was not made payable to the plaintiff and contained no endorsement even though the original note endorsed in blank was introduced at trial holding that because a mortgage provides the security for the repayment of the note the person having standing to foreclose a note secured by a mortgage may be either the holder of the note or a nonholder in possession of the note who has the rights of a holder holding that there is no impermissible modification of the note because the very terms of the note allow for prepayment without a penalty