In re: TERRORIST ATTACKS ON SEPTEMBER 11, 2001., 2012 WL 257568 (2012) Coca-Cola Co., 578 F.3d 1252, 1258 n.5 (11th Cir. 2009) (allowing TVPA action against corporate defendant), and Khulumani, 504 F.3d at 260, with Mohamad v. Rajoub, 634 F.3d 604, 607-08 (D.C. Cir. 2011) (holding that TVPA liability does not extend to non-natural persons), and Aziz v. Alcolac, Inc., 658 F.3d 388, 392 (4th Cir. 2011) (same), and Bowoto v. Chevron Corp., 621 F.3d 1116, 1126-27 (9th Cir. 2010) (same). In the interest of judicial economy, plaintiffs respectfully request that this Court defer deciding their appeal of the dismissal of ther TVPA claims until the Supreme Court has decided Mohamad and the Court can obtain the benefit thereafter of the parties’ views of the implications of that decision for this case. Alternatively, should Mohamad not result in an opinion or if this Court is inclined to reach a decision on the TVPA claims independently of Mohamad, it should vacate the district court’s dismissals. The TVPA *138 creates an action in tort and, therefore, should be interpreted in light of the well-established common law (and international law) presumption that organizations are liable in tort for the acts of their agents. See Balt. & Potomac R.R. v. Fifth Baptist Church, 108 U.S. 317, 330 (1883); Br. for Petitioners at 12-17, Mohamad v. Palestinian Authority, No. 11-88 (Sup. Ct. Dec. 14, 2011) (“Mohamad Br.”). Moreover, the TVPA’s use of the term “individual” comports with this presumption because this term has often been construed as synonymous with the term “person,” which has a broad legal meaning that includes organizational entities, such as corporations. See, e.g., Clinton v. City of New York, 524 U.S. 417, 428 & n.13 (1998); Mohamad Br. at 19-20 (citing cases from federals courts of appeals); see also id. at 17-18 (noting that dictionary definitions of the word “individual” often include non-natural entities). Furthermore, such a broad interpretation is consistent with th