Garuda Indonesia Flight 152 is wholly owned by the Indonesian government, could be held liable under two exceptions to the Foreign Sovereign Immunities Act. She contended that because Garuda was authorized to operate in the United States at the time, the immunity had been explicitly waived under the rules of the Department of Transportation, which requires foreign air carriers to open themselves to suit in the United States as a condition of being allowed to fly to, from, or within this country. The waiver is limited to actions arising under treaties. Coyle also claimed that by selling tickets in the United States, Garuda waived
Garuda Indonesia Citilink, which provided low-cost flights to multiple Indonesian destinations and was spun-off in 2012. The earliest predecessor to Garuda Indonesia was KNILM, Royal Dutch Indies Airways, founded in 1928 during the Dutch colonial period; despite the similar name, it was not a subsidiary of the main Dutch carrier KLM. KNILM was dissolved in 1947, and its assets were transferred to a new KLM subsidiary, KLM Interinsulair Bedrijf (KLM Interinsular Service), which was nationalized in December 1949. The name "Garuda" was derived from a Dutch poem written by a renowned Javanese scholar and poet Raden Mas Noto Soeroto; ""Ik ben Garuda,