id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-2949	Goldberg, Victor P.	The Empagran Exception: Between Illinois Brick and a Hard Place	2009	17	.pdf	application/pdf	5576	253	58	In addition to substantial criminal sanctions, cartel members paid over $2 billion to American plaintiffs.2 When foreign plaintiffs tried to sue the foreign defendants in American courts, however, they encountered resistance.' 7 Compare Kruman v. Christie's Int'l, 284 F.3d 384 (2d Cir. 2002) (holding that foreign plaintiffs could sue), with Den Norske Stats Oljeselskap As v. HeereMac Vof, 241 F.3d 420 (5th Cir. 2001) (dismissing foreign plaintiffs claim for lack of subject matter jurisdiction).	cache/cblr-2949.pdf	txt/cblr-2949.txt