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In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) Qaida’s operations, and consequently that the accounts maintained by Al Rajhi Bank on behalf of *103 those organizations were being used to channel funds to al Qaida.” JA3828. Plaintiffs made further allegations connecting the Al Rayhi family, “which owns and controls Al Rajhi Bank,” to al-Qaeda, including that they have ties to Osama bin Laden’s personal secretary, are major donors to the SAAR network, and are closely associated with wealthy donors to Osama bin Laden identified on the Golden Chain. SPA56 (Terrorist Attacks I); JA1081-85; Companion Brief at Point LB.2(c). The district court found such allegations to be insufficient because plaintiffs did not also provide “allegation[s] that the family members were acting in furtherance of Al Rajhi Bank business.” SPA57 (Terrorist Attacks I). The district court missed the point entirely, though, in focusing on the family members’ actions and whether they furthered the bank’s business. As the D.C. Circuit found in A/-Adahi, these allegations of the family members’ affiliations and patterns of behavior paint a mosaic revealing intimate involvement with al-Qaeda. As a result, these allegations support a reasonable inference that defendants’ provision of material support to al-Qaeda was done either knowingly or recklessly. *104 The district court made the same error in finding insufficient allegations that Al Rajhi Bank provided material support to Hamas and other terrorists, including through provision of funds to Tulkarm Charity Committee, a known front for Hamas. SPA56-57 (Terrorist Attacks I); JA1077-79. Plaintiffs also alleged that Al Rajhi Bank hosted its website with Infocom, a Texas-based company owned and operated by Mousa Marzook, a Hamas leader and designated terrorist. SPA56 (Terrorist Attacks I); JA1077-78. Infocom has provided funding to Hamas, and Al Rajhi Bank has made transfers from its accounts to Marzook and Infocom. SPA56 (Terroris

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