from asserting a claim under rico nor does it specifically limit its application to u s persons or entities in all i j on the biscoe the supreme court explicitly stated that it's requirement of a domestic injury does not preclude a foreign person or entity from asserting it playing for rico however the way in which the district court below defines domestic injury it does just that every single time uniformly in the application the federal statute is key with regard to rico congress intended it to be broadly applied by applying state working to determine what such the locational nexus that a legit injury should be the plainness residence of course which here is is far and i want to ask you is the domestic injury in this case to pander on the fact that the our patrol award was recognized in new york on another words would we have a domestic injury if  so we feel we have a very legitimate retorted you you have argued that the property interested issue here is the judgement the awards and the litigation right aren't goa which you say you agree with i agree with the second circuit decision this can and i don't agree with the lower court decision well from but we have cases such as the baldwin case and the keystone white case in this jurisdiction and other cases we cited that say that cause of action or property you have to take tongue case which says that the judgment is property we submitted these these are properties needs a tangible properties a us judgment is an asset it's something very tangible prior to the judgment and the arbitration awards how then could those allegations relate to an injury to the property interests that you are alleging here benefit the joint venture is in india and them call themselves uniformity in the application the federal state and the federal statute is key with regard to rico congress intended it to be broadly applied by applying state law to determine whether a plaintiff has asserted the mystic injury the ability to uniformly interpret a federal statute has me constricted the court below restricted the use of rico to only u s citizens in violation of the supremacy clause of the united states thus if a model was a property the court below did not dispute this because defendants wrongful conduct and good plaintiffs cooperate located in the united states on mata has alleged a domestic injury the decision the court below should be reversed  presumption against extraterritoriality that was applied in r g r j aren't riscoe would be nothing more than a pile of shredded wheat let's look at the nature of the injury here these parties  a and the plaintiff appellant entered into a contract in two thousand and eight in south asia for the delivery of oxide in south asia no us involved there were breaches of that contract and those breaches w injury to the plaintiff is the failure to collect the foreign debt simply domesticating a judgment in the united states does not domesticate a foreign  have any meaning at all now the absolutely if if out here where do you think or money can bring an action for the conduct by the defendants is there is there a forum available to redress  proceeding involving asher poor where presumably its creditors came forward in asserted their claims some of the complaints about my client's conduct have to do with the chapter fifteen proceeding in the united the over the objection to us administration made by the appellant so again everything about this case virtually is has to do with foreign conduct in the end any injury here has to be categorized foreign if our g r nabisco is will it have any meaning at all now in the appellant's brief the district court is faulted for applying conflict of law principles to the determination of where the injury was suffer there's no reason at all why those principles shouldn't have some value in determining where an injury was suffered because conflict of law rules are often engaged in just that in the district court properly looked to a long line of cases applying the restatement of conflict of laws to reach the determination that the injury must be suffer at the principal place of business now the  district court did not apply a categorical rule that every injury of a financial nature is suffered at the principal place of business of the plaintiff the district judge held generally that so there's no reason it shouldn't be so here where there are significant connections between the plaintiff's residence and the matters that originated the injury let's remember this was a singapore indian transaction and applying and determining that any injury from breach of that original contractual relationship occurred in singapore is completely fair and send and the district court applied that correctly the best union decision is quite helpful our side your honor we think that the that the question was asked about its applicability we think that the rule applied by the second circuit tangible property only has no applicability to the intangible bundle of litigation rights that the appellant is asserting here the property involved the injury involved in best kunin that the court upheld the cup that the court held could go forward at least after the fleeting us involved the theft of bear securities from a new york bank deposit box and the theft of money from a new york bank account the court went on it some way to explain that the downstream effects from an original foreign injury are not a domestic injury in the united states and specifically in that case there were there were allegations of money laundering going on funds stolen by the defendant allegedly in the best case and laundered through new york banks or a new york financial institution second circuit said that doesn't change the basic foreign injury into a domestic injur think that ruling is send there are a number of cases since our jr came out in june of two thousand and sixteen that applied the concept of downstream injuries that is where there is an original foreign injury it doesn't become a domestic injury because the money or other valuables are pursued into the united states those downstream effects several courts and we've cited the district court cases in our brief and we think best in applies the same rule without using the word downstream but it basically applies the same rule and it's a sound one that those later effects that follow after the original injury should not to the residence of the plaintiff your honor that was that was the ruling in this case by the district court we think it's a sound one it doesn't necessarily have to apply without qualification in every single situation but here we have in addition to that relationship between the injury and the principal place of business of the appellant we also have the significant other connections between this matter and the injuries involved and singapore where the appellant as its principal place of business that's where they're the transaction originated that led to the breach that led to the injury that led to the arbitration award and eventually swam downstream to the united states in the form of of these the of these claims the other then the hiring lawyers in the united states the appellate never conducted any business that's has never set foot so there's no claim of any injury to business in the united states there's a claim of injury to property the property consists only of the bundle of litigation rights that the appellant received when it domesticated its foreign arbitration awards and so we would ask the court to hold that merely domesticating a judgment does not turn a foreign injury into a domestic injury and we ask the court  to point out to the court that the chip to check the fifteen petition was dismissed because all modern ayesha poor and am called exhibit bad faith in not complying with the court's orders so the same type of conduct they conducted towards all mada they conducted towards the bankruptcy court in new york who dismissed and i think the only thing that the fifteen dismissed as far dismissed that chapter fifteen petition to allow parties contracts from dollars to euros because euro's cannot be attached under american maritime law this is the kind of conduct they engaged in and as far as downstream conduct is concerned it's the conduct that we are citing here before this court and they're not briefs that is what why we're still in here if they had not depleted the assets back to poor to benefit themselves with been able to enforce  judgments and course of action and litigation rights but instead like other parties that we're left holding the bag that we don't get anything out of it basically we had one positive of collection here in illinois in chicago who with the root payment of excess proceeds on a dividend payment we were successful in getting to turn over all of those funds by the court but well but other than that that was it none of these m