The survivors of the trial tried to bring a number of legal actions against Pfizer in the United States. These resulted in four judicial opinions, the first three dismissing the claims on procedural grounds. According to Ben Goldacre, Pfizer argued that it was not required to obtain informed consent for experimental drug trials in Africa, and that any case should be heard in Nigeria. In May 2006 Representative Tom Lantos of California, the senior Democrat on the House International Relations Committee, described the findings of a report compiled about the case by the Nigerian government as "absolutely appalling" and called for Pfizer to open its records. In January 2009 the United States Court of Appeals for the Second Circuit ruled that the Nigerian victims and their families were entitled to bring suit against Pfizer in the United States under the Alien Tort Statute. Pfizer subsequently settled the case out of court with a $75 million settlement that was subject to a confidentiality clause.