Kadic v. Karadzic, 70 F.3d 232, 239 (2d Cir.1995), the Second Circuit held that, for certain categories of action, including genocide, the scope of the law of nations is not confined solely to state action but reaches conduct of private individuals. Other circuits have since elaborated upon this finding. See Sinaltrainal v. Coca-Cola Co., 578 F.3d 1252, 1266-67 (11th Cir.2009) (stating that “plaintiffs need not plead state action for claims of torture and murder perpetrated in the course of war crimes”); Abdullahi v. Pfizer, Inc., 562 F.3d 163, 188 (2d Cir.2009) (finding that a private individual will be held liable under the ATS if he “acted in concert with” the state, that is, “under color of law”) (citations omitted); Abagninin v. AMVAC Chem. Corp., 545 F.3d 733, 741 (9th Cir.2008) (<HOLDING>); Doe v. Unocal Corp., 963 F.Supp. 880, 891-892
holding that because it fell within the exclusive jurisdiction of the united states court of international trade the united states court of federal claims lacked jurisdiction over a matter that was protested or protestable holding that the district court correctly found that defendants were not states or statelike organizations for purposes of international law or crimes against humanity under ats holding that the elements of a claim under  3729a2 are 1 that the defendant made used or caused to be made or used a record or statement to get a claim against the united states paid or approved 2 the record or statement and the claim were false or fraudulent and 3 the defendant knew that the record or statement and the claim were false or fraudulent emphasis added holding that the ats does not waive the united states sovereign immunity holding that district court correctly concluded that it could not order the government to grant use immunity