Whether a defendant that provides generic, widely available services to all its numerous users and 'regularly' works to detect and prevent terrorists from using those services 'knowingly' provided substantial assistance under Section 2333

QUESTIONS PRESENTED Under Section 2333 of the Anti-Terrorism Act, as amended by the Justice Against Sponsors of Terrorism Act, U.S. nationals injured by “an act of international terrorism” that is “committed, planned, or authorized by” a designated foreign terrorist organization may sue any person who “aids and abets, by knowingly providing substantial assistance, or who conspires with the person who committed such an act of international terrorism,” and recover treble damages. 18 U.S.C. § 2333(a), (d)(2). The questions presented are: 1. Whether a defendant that provides generic, widely available services to all its numerous users and “regularly” works to detect and prevent terrorists from using those services “knowingly” provided substantial assistance under Section 2333 merely because it allegedly could have taken more “meaningful” or “aggressive” action to prevent such use. 2. Whether a defendant whose generic, widely available services were not used in connection with the specific “act of international terrorism” that injured the plaintiff may be liable for aiding and abetting under Section 2333. @