Cir. 1996) (requiring for implied waiver a “close relationship” between a written agreement and United States litigation); Unlike in Siderman de Blake, the Indian government did not directly file documents in a court of the United States for the purposes of effecting Barapind’s extradition. Instead, the Indian government used diplomatic channels to request Barapind’s extradition from the United States, and the United States government “filed a complaint on India’s behalf’ in district court, seeking a certificate of ex-traditability. See Barapind, 400 F.3d at 747. This use of diplomatic channels does not, on its own, create the necessary relationship between the Indian government and our courts. See Blaxland v. Commonwealth Dir. of Pub. Prosecutions, 323 F.3d 1198, 1206 (9th Cir. 2003) (<HOLDING>). Because the Understanding does not expressly
holding that a claim that sovereign immunity has been waived is itself waived if not argued on appeal holding that the doctrine of sovereign immunity barred a claim for money damages against the librarian of congress in his official capacity because immunity had not been waived and the exceptions to immunity did not apply holding that state waived its immunity by filing proofs of claim holding that australiahad not impliedly waived its immunity when it used diplomatic channels to effect extradition recognizing that immunity may be waived