you not reserved any time for rebuttal i have reserved two minutes two minutes ok all right so you've got three minutes the court room deputy will let you know sort of a minute before you hit the different  district court's decision is its conclusion that the prospectus only applies to bonds sold in the united states the district court wrongly interpreted the prospectus which is a matter of law waiver of sovereign immunity in the prospectus is clear and unambiguous the bonds which it covers are not limited in any way the district court reached its incorrect conclusion by relying on language in the prospectus referring to a separate underwriter will call it israel bonds international and that underwriter is for bond sold outside the united states as mentioned at page a one hundred and seventy five dollars of the joint appendix but there is no design voyage in the prospectus or in the record that says whether the prospectus was used outside the us or not used the wording in the prospectus does not say that i b i will not provide a copy of this prospectus it says prospectus is that's a quote the word prospectuses and various forms are available outside of the united states from local underwriters now at the same time the record shows that the prospectus is available on the internet at w w w dot israel bonds dot com and we know through edgar in the decision of the district  sold in the us this conclusion is bolstered by the fact that in the prospectus when israel wanted to make clear what the waiver did not cover it expressly stated that at page hundred and seventy six dollars the prospectus states israel has not waived its sovereign immunity in connection with any action arising out of or based on united states federal or state security slugs the situation we have here is similar to that presented in this court's decision in capital ventures versus republic of argentina in that case the district court dismissed the claims on bonds issued by argentina under german law for lack of subject matter jurisdiction the capital venters case is analogous because the waiver had broad and clear mind wage and it referred to a waiver as to any this court refused to conclude that the form selection of a court in germany restricted that language in appellants case we have the language that the waiver applies to any  of any issue and that language is not restricted elsewhere in the prospectus this prospectus never says that it only applies to bonds in the u s the district course interpretation of the prospectus that it applies only to domestically sold bonds is not supported by the language in the perspective the correct interpretation is that the prospectus is not limited to bonds sold in the u s consequently israel's explicit waiver covers the action that appellant filed in the southern district and the district court should be reversed all right let's take a break here and we israel what do i have to do to collect on these bonds and it's a perspective that was publicly available and said that there is a waiver of sovereign immunity for actions that she found in argentina and she saw that she could sue in the southern district of new york where there was a waiver of foreign sovereign immunity and that's that's what happened that's in the record and she understood that that is able her to bring the case in the southern district because foreign sovereign immunity was waste here on any bonds of any issue and that was in a prospectus for the question isn't isn't that perspective specifically tied to the offering of the bond separate soul in the united states it speaks in that same page i believe you're so looking at one  to the bonds that our clients had and that when they were seeking their remedy they saw that in a do you believe balance prospectus this is what is written and that same prospectus does not in the southern district under the law of a strong feel as covered in detail in our brief israel express leeway to sauber an immunity as to bonds purchased anywhere in the world this is shown by  e prospectus found in canada for canadian purchase bonds is there is a and that perspective step we're looking at now in the fiscal agency agreement which is referred to in the forms of the ballance there is a waiver of sovereign immunity and so the only question really that is out there is we're surprised st place to sue it when israel argues that the proper place is ontario canada which is what israel did argue to the district court and under the law of the stoppel in cossack oh versus new rochelle radiology the court m parse this out there's a waiver as to bonds purchased anywhere in the world through various documents that can be clearly seen the question then where do you think an action should take it selection forum selection is not waiver of sovereign immunity it's where can israel be sued they expressly way the foreign sovereign immunity as to actions under any bonds of any issue but where those claims are brought in fact it boils down to two jurisdictions when you take all the waivers together so what seems to be happening is that there's two places to sue the place in canada and was hidden from our clients this is not part of waiving sovereign immunity it's for him to sue and  if since it was hidden then certainly that leaves our clients with the remaining publicly known then you suing in the southern district heard from your adversaries thank you thank you panamanian litigation instituted by the appellate grandfather affidavit submitted in connection with the motion by computershare the development corporation of israel as well as the attorney  that the labor contained in the seven series prospectus should be read more broadly and that the term quote the bonds close quote and the use of that term means that the waiver contained in that respect and supplies to the waiver that applies to the bond contained in that document extends only as far as the scope of the prospectus which is the seven series jubilee sold in the united states  these claims but i would know that they have filed suit in argentinean court against the grandfather seeking both criminal and civil liability and my interpretation is that the appropriate suit progress for  seem to build a case and the language says in any israel era vocally agree not to serve a defense of immunity on a munity including foreign sovereign immunity from jurisdiction which might otherwise be but you're your opponent then goes on and says to the rest that certain streets which may be instituted by the owner of any violence of any issue in any federal court in the southern district of new york  centric country what's the what's the why is that language why it is why is it may be instituted by the owner of any bonds of any issue i mean that that means of i don't understand why the term of any any issues in there it introduces to me some ambiguity your honor israel's position is that the perspectives in the perspective supplement need to be read as a whole and i believe the language you're referring to references back to the fact that perspective pertains to the seven series jubilee bonds but it also describes that there are multiple issue in states that will apply to the bonds and they're described respecters it also points st the computershare defendants were properly dismissed from the case of having absolutely nothing to do with these international bonds and nd to address the district court's proper dismissal of any further really think leading commission to here this morning the computershare us senate is were not that the agents for the bombs that issue in this case the document the plaintiff attached to their complaint the us the school agency agreement itself establishes that fact by attached at eight dollars to seventy seven dollars plaintiffs counsel was told that these were international share international sales through r b i and that computershare kandahar was the fiscal agent they also received a check in two thousand and fourteen from computershare trust company canada there was never anything hidden about that fact and in fact the very st time the plaintiffs contacted computershare us by serving a subpoena in january of section of our foreign entity because of the single bank transaction is not a suitable basis for personal jurisdiction that's kind of classically within the definition of random fortuitous an atten intended for use in connection with sales of bonds only in the united states that's what he said the problem is that mr monti paragraph three of his declaration defines us prospectus as the prospectus found with the s e c that my client in argentina saw and he comes behind it with the prospectus supplement in other words when he says that it was intended for use in connection with sales of blind only in the united states he's talking about the come combination which we have never said the combination is what we are our clients look to our clients look at simply talks about that excuse me i want to go to judge wesley point about the mention of the bonds and using sort of a generic word the bonds and if you look at the prospectus it recently he did have one more that takes me to has their statement when she said that we don't complain that payment was improper we certainly do that's their position that payment was not improper we believe the payment not properly made there wasn't the care that would be required for a securities intermediary sent to a corporate account in panama with respect to  the state that was pending in argentina this certainly raised red flags that were never checked on finally mr lott again said that well the i have faith doesn't support  e waiver or rights for our clients well if that's the case well then more than ever the broad language of the waiver that says bond of any issue in any action brought in the southern district that there is a waiver of foreign sovereign immunity so if it's not available anywhere else it makes it much more clear that this waiver was intended to have broad