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IN RE TERRORIST ATTACKS ON SEPTEMBER 11, 2001 815 Cite as 349 F.Supp.2d_ 765 (S.D.N.Y. 2005) ton Plaintiffs bolster their arguments for personal jurisdiction by citing to para- graphs in the complaint in support of each of the requirements for conspiracy. See Chrysler Capital Corp, T78 F.Supp. at 1268-69 (outlining cause of action for con- spiracy). Plaintiffs claim that Prince Mohamed and al Qaeda agreed to injure the United States through acts of international terror- ism. Ashton Complaint 195, 28 (all defen- dants are co-conspirators), 51, 105-08 (February 1993 World Trade Center bombing), 120 (February 1998 fatwa), 130- 36 (998 embassy bombings), 152-55 (U.S.S. Cole attack), 188, 255, 274~76, 580 (September 11, 2001 attacks); see also Federal Complaint 11 66, 72-74 (listing de- fendants who have “aided and abetted, conspired with, and provided material sup- port and resources to, defendant al Qaeda and/or affiliated FTOs, associations, organ- izations or persons.”). Next they claim the September 11 attacks were perpetrat- ed in furtherance of that common scheme. Ashton Complaint 1928, 188, 610. Ac- cording to Plaintiffs, Prince Mohamed par- ticipated in the conspiracy by providing funding, financial support, and banking services through FIBS. /d. 1948-54, 63- 66, 255, 274-276, 387, 580, 582. Specifical- ly, Plaintiffs claim: @ On October 17, 1983, Prince Mohamed became CEO of DMI. Under Prince Mohamed’s chairmanship, DMI devel- oped banking, investment and insur- ance activities in approximately twenty offices across the world. DMI was founded in 1981 to foster the spread of Islamic banking across the Muslim world and its Board of Directors in- cluded Haydar Mohamed bin Laden, a half-brother of Osama bin Laden. Jd. 1 274. @ Faisal Islamic Bank Sudan was one of the five main founders of Al Shamal Islamic Bank .... Al Shamal Islamic Bank is an instrumental bank in bin Laden’s financial support network. Bin Laden used Al Shamal Bank for the funding of his al Qaeda network leading up to the 1998 United States embassy bombings in Africa. Defen- dant Faisal Islamic Bank was implicat- ed during Al Fadl’s May 2001 United States trial testimony regarding the bombings as holding and managing bank accounts for al Qaeda operatives. Id. 19 274-75. e As the head of DMI, Prince Mohamed knew or should have known of these and other activities and acted as an aider and abettor and material sponsor of al Qaeda, bin Laden, and interna- tional terrorism. Id. {1 276. @U.S. designated terrorists Wa‘el Julai- dan and Yassin Kadi had accounts in a DMI subsidiary. Ashton Opp. at 25. Finally, Plaintiffs allege the that attacks in question caused many deaths, a fact that no one disputes. Ashton Complaint 11 23, 610. In response, Prince Mohamed argues that Plaintiffs have failed to demonstrate that he is “present” in the United States for general personal jurisdiction purposes. See Helicopteros Nacionales de Colombia, S.A. v. Hall, 466 U.S. 408, 411-12, 416-18, 104 S.Ct. 1868, 80 L.Ed.2d 404 (1984); Bersch v. Drexel Firestone, Inc., 519 F.2d 974, 998 (2d Cir.1975) (buying and selling American securities is insufficient to estab- lish that defendant was “doing business” in the United States). Prince Mohamed sub- mits that some of the contacts on which Plaintiffs rely are too far removed in time from September 2001 to be considered by the Court. See Metro. Life, 84 F.3d at 569 (holding courts should examine a defen- dant’s contacts with the forum for a rea- sonable period prior to the date on which the lawsuit was filed, and finding that six HOUSE_OVERSIGHT_017880