‘virtually unanimous’ precedents construing the implied waiver provision narrowly.” Id. (quoting Shapiro v. Republic of Bolivia, 930 F.2d 1013, 1017 (2d Cir.1991)). Courts have found implied waiver where a foreign state has filed a responsive pleading without rais ing the defense of sovereign immunity. Id. at 123. They have also found implied waiver where the state has agreed to arbitrate or to adopt a particular choice of law, under circumstances not present in this case. Id.; see id. at 122 (" '[M]ost courts have refused to find an implicit waiver of immunity to suit in American courts from a contract clause providing for arbitration in a country other than the United States.’ " (quoting Frolova v. Union of Soviet Socialist Republics, 761 F.2d 370, 377 (7th Cir.1985))); id. at 126 (<HOLDING>). As we have also noted, " ‘courts have been
holding that an act of legislature may be required to waive sovereign immunity holding that a state may waive its sovereign immunity holding that removal to federal court does not waive tribal sovereign immunity holding that the lanham act did not waive states sovereign immunity holding that qatar did not by agreeing to arbitrate in france waive its sovereign immunity under  1605a1