In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) Argument I. The District Court Improperly Dismissed the Anti-Terrorism Act Claims The Anti-Terrorism Act (“ATA”), 18 U.S.C. § 2333 ef seg., provides a cause of action for treble damages for those injured in their person, property, or business by acts of international terrorism, and it was designed especially for claims against material supporters of terrorist organizations. Plaintiffs allege that defendants knowingly provided just such material support to al-Qaeda, rendering them liable for injuries that plaintiffs suffered as a result of the September 11, 2001 attacks. The district court erroneously dismissed plaintiffs’ ATA claims against Al Rajhi Bank,'* Saudi American Bank,'* Dar Al-Maal-Al-Islami Trust (“DMI *64 Trust”),'°° Saleh Abdullah Kamel,!” and Dallah al Baraka Group L.L.C. (“Dallah al Baraka’’).!° It did so primarily on the ground that plaintiffs did not adequately allege that Defendants knew that the recipients of their support advanced al-Qaeda’s activities -- despite plaintiffs’ detailed pleading of Defendants’ extensive dealings with al-Qaeda and its network of supporting entities. As shown below, the district court’s rulings are based on fundamental legal errors regarding the standard of review and appropriate treatment of plaintiffs’ allegations, misconstrue the ATA, and ignore plaintiffs’ detailed pleadings that squarely place defendants at the heart of the network of persons and organizations that supported al-Qaeda. A. The ATA Is Construed Broadly and Readily Encompasses Defendants’ Alleged Conduct The question whether a claim has been stated based on a statutorily-created cause of action turns on Congress’s intent regarding the scope and operation of the cause of action. Abrahams v. Young & Rubicam Inc., 79 F.3d 234, 237 (2d Cir. 1996). Congress without doubt intended the ATA to *65 be construed broadly and to provide a cause of action based on conduct that includes the sup