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826 nett I, 274 F.Supp.2d at 104. Proximate cause will support this connection. See Furst Nationurde Bank v. Gelt Funding Corp., 27 F.3d 763, 769 (2d Cir.1994) (“Central to the notion of proximate cause is the idea that a person is not liable to all those who may have been injured by his conduct, but only to those with respect to whom his acts were a substantial factor in the sequence of responsible causation, and whose injury was reasonably foreseeable or anticipated as a natural consequence.”). In light of al Qaeda’s public acknowledg- ments of its war against the United States, the September 11 attacks may be the natu- ral and probable consequence of knowingly and intentionally providing material sup- port to al Qaeda. Burnett [, 274 F.Supp.2d at 104. [72] Plaintiffs rely on theories of con- certed action liability—conspiracy and aid- ing and abetting—in support of this causal link. “Concerted action liability under New York law is based on the principle that ‘[a]ll those who, in pursuance of a common plan or design to commit a tor- tious act, actively take part in it, or further it by cooperation or request, or who lend aid or encouragement to the wrongdoer . are equally liable with him’” Putt- man, 149 F.3d at 122 (quoting Bichler v. Eli Lilly & Co. 55 N.Y.2d 571, 580, 450 N.Y.S.2d 776, 486 N.E.2d 182 (1982)). To be liable under either conspiracy or aiding and abetting, however, the defendant “must know the wrongful nature of the primary actor’s conduct,” 2d. at 128, and the conduct must be tied to a substantive cause of action, Chrysler Capital Corp., 778 F.Supp. at 1267. In this regard, Plain- tiffs rely on the ATCA, RICO, the TVPA, the ATA, and various state laws, including wrongful death, survival, intentional inflic- tion of emotional distress, trespass, assault and battery, negligence, and negligent in- fliction of emotional distress. 349 FEDERAL SUPPLEMENT, 2d SERIES 1. ATCA [73] The Alien Tort Claims Act pro- vides that “[t]he district courts shall have original jurisdiction of any civil action by an alien for a tort only, committed in viola- tion of the law of nations or a treaty of the United States.” 28 U.S.C. § 1350. “This statute confers subject matter jurisdiction when the following three conditions are satisfied: (1) an alien sues (2) for a tort (3) committed in violation of the law of nations (i.e., international law).” Kadic v. Karad- zic, 70 F.8d 232, 238 (2d Cir.1995); see also Flores v. Southern Peru Corp., 348 F.3d 140, 143 n. 2 (2d Cir.2003). Certain Plaintiffs in these actions are aliens and the complaints all allege common law torts. The Court finds that “aircraft hijacking is generally recognized as a violation of inter- national law.” Burnett I, 274 F.Supp.2d at 100 (citing Kadic, 70 F.3d at 240; Bigio v. Coca-Cola Co., 239 F.3d 440, 447-49 (2d Cir.2000)). Further, “courts, including the Second Circuit, have almost unanimously permitted actions premised on a theory of aiding and abetting and conspiracy.” Presbyterian Church of Sudan v. Talrs- man Energy, Inc., 244 F.Supp.2d 289, 311 (S.D.N.Y.2003). Accordingly, the ATCA may provide a basis for a concerted action claim of material support by alien-Plain- tiffs here. See Burnett [, 274 F.Supp.2d at 100. 2. RICO “To state a claim under civil RICO, a plaintiff must plead seven elements: (1) that the defendant (2) through the commis- sion of two or more acts (8) constituting a ‘pattern’ (4) of ‘racketeering activity’ () directly or indirectly invests in, maintains an interest in, or participates in (6) an ‘enterprise’ (7) the activities of which affect interstate or foreign commerce.” Berk v. Tradewell, Inc., Nos. 01 Civ. 9035, 01 Civ. HOUSE_OVERSIGHT_017891