nigerian litigation as zango v. pfizer (zango litigation). the zango litigation had recently been dismissed in nigeria. the court declined to take judicial notice of the "zango litigation", instead opting to vacate the district court's dismissal on grounds of forum non conveniens and remanding the case to the district court to consider the implications of the "zango litigation" on its forum non conveniens analysis. for these reasons, the court of appeals vacated and remanded to the district court. abdullahi v. pfizer, inc. iii after the court of appeals vacated and remanded, the district court readdressed the dual grounds for dismissal, both dismissal pursuant to rule 12(b)(6) of the federal rules of civil procedure and dismissal pursuant to the doctrine of forum non conveniens. on remand, the district court granted pfizer's dismissal under rule 12(b)(6) and found that the zango litigation did not preclude dismissal for forum non conveniens. adequate alternative forum analysis after setting forth the factual and procedural background the district court turned its attention to the zango litigation. the court's somewhat searching review of the zango litigation came in direct response to the court of appeals holding, which questioned whether nigeria was in fact an adequate alternative forum, because the "zango litigation" had ended in dismissal. the district court discussed the "zango litigation"'s procedural history, concluding that the plaintiffs’ filed a notice of discontinuance, based upon the federal high court, "having declined jurisdiction in this matter for personal reasons". next, the court addressed the plaintiff's allegations of corruption within the nigerian judiciary. although plaintiff's provided allegations of corruption and anecdotal evidence, the court ultimately held that plaintiffs were unable to establish corruption and bias in the "zango litigation". finding instead, that dismissal was a result of the plaintiff's waiting "endlessly for a new judge to replace judge hobon", who had recused himself for personal reasons. for these reasons, the district court, again found that nigeria provided an adequate alternative forum. applying sosa u.s. supreme court building in finding that dismissal was also appropriate under for lack of subject matter jurisdiction, which the court mistakenly refers to as federal rule of civil procedure 12(b)(6), the court relied heavily upon sosa. under sosa, the alien tort claims act creates no new causes of action but confers on federal courts the power to hear a narrow set of alien tort claims for violations of international law. however, the supreme court did leave the door open for courts, exercising a vigorous gatekeeping function, to recognized new actionable rules based on evolving principles of international law. however, "federal courts should require any claim based on the present-day law of nations to rest on a norm of international character accepted by the civilized world and defined with a specificity comparable to the features of the 18th-century paradigms". having set forth the relevant standard, the court evaluated whether pfizer did in fact violate customary international law. first, the district court found that the nuremberg code, which governs scientific research on human subjects, does not contain a private cause of action. second, the district court found that the declaration of helsinki and the cioms guidelines does not contain a private cause of action. instead, finding these guidelines are merely a "general statement of policy that is unlikely to give rise to obligations in any strict sense". third, the district court found that the iccpr was not "self executing" and that a private right of action should not be implied. finally, the district court found that the universal declaration of human rights does not impose obligations as a matter of international law. instead, it is "merely aspirational". none of the sources of international law cited by the plaintiffs were a proper predicate for jurisdiction under the alien tort claims act. for the reasons discussed, the court granted pfizer's motion to dismiss, for failure to state a claim under the alien tort claims act and, even if subject matter jurisdiction were found, the action would be dismissed on forum non conveniens grounds (under the same conditions set forth in abdullahi i). ajudu ismaila adamu v. pfizer, inc. the district court recites the facts set forth in abdullahi i, and the analysis of the alien tort claims act set forth in abdullahi iii, before turning to the claims under the connecticut unfair trade practices act and the connecticut products liability statute. the court began by analyzing connecticut's choice of law principles. under connecticut's qualified lex loci delicti doctrine, the district court concluded that nigerian — not connecticut — substantive law governs, and accordingly, both connecticut law claims were dismissed. in addition to lack of subject matter jurisdiction, under both the alien tort claims act and the connecticut statutory causes of action, the court also granted the motion to dismiss on grounds of forum non conveniens, with the same additional conditions required by abdullahi i and abdullahi iii. nigerian government lawsuit on 5 june 2007, the government of nigeria filed against pfizer in the nigerian federal high court, seeking us$6.95 billion in damages. nigeria claimed that pfizer "never obtained approval of the relevant regulatory agencies... nor did the defendant seek or receive approval to conduct any clinical trial at any time before their illegal conduct". after preliminary arguments, the case was adjourned until 26 june of that year. 2009 settlement in february 2009, pfizer decided to settle its legal case with the 200 plaintiffs. an out-of-court settlement was reached, and scheduled to be put in writing at a meeting in rome, italy in march 2009. the settlement followed months of negotiations between pfizer and the kano state government which represented the plaintiffs. according to wikileaked us embassy cables, pfizer's country manager admitted that "pfizer had hired investigators to uncover corruption links to federal attorney general michael aondoakaa to expose him and put pressure on him to drop the federal cases". the talks were brokered by the former nigerian military leader yakubu gowon and the former u.s. president jimmy carter. the lawyer representing the nigerian government was babatunde irukera. in october 2009, the medical records of the victims of the 1996 pfizer trovan clinical trial could not be found at the kano state ministry of health nor at the infectious diseases hospital (idh) where the trials were conducted, according to the state's attorney general and commissioner for justice barrister aliyu umar, shortly after umar confirmed that the state government had received $10 million from pfizer as part of the $75 million settlement of the protracted dispute. the nigerian government conducted their own investigation, whose report was kept secret for five years with the only three printed copies being lost.