The U.S. District Court for the E.D.Va. has since been overturned: "On May 23, 2012, the United States Court of Appeals for the Fourth Circuit issued an opinion vacating the Court's dismissal of the piracy count. United States v. Said, 680 F.3d 374 (4th Cir.2012). See also United States v. Dire, 680 F.3d 446, 465 (4th Cir.2012) (upholding an instruction to the jury that the crime of piracy includes "any of the three following actions: (A) any illegal acts of violence or detention or any act of depredation committed for private ends on the high seas or a place outside the jurisdiction of any state by the crew or the passengers of a private ship and directed against another ship or against persons or property on board such ship; or (B) any act of voluntary participation in the operation of a ship with knowledge of facts making it a pirate ship; or (C) any act of inciting or of intentionally facilitating an act described in(A)or(B) above")." The case was remanded to E.D. Va., see US v. Said, 3 F. Supp. 3d 515 – Dist. Court, ED Virginia (2014).