The question whether a claim has been stated based on a statutorily-created cause of action turns on Congress’s intent regarding the scope and operation of the cause of action. Abrahams v. Young & Rubicam Inc., 79 F.3d 234, 237 (2d Cir. 1996). Congress without doubt intended the ATA to *65 be construed broadly and to provide a cause of action based on conduct that includes the support provided to al-Qaeda alleged in the complaints and associated pleading materials in this case.
 
The ATA is directed at preventing and providing recovery for acts of material support to terrorism, broadly defined. Congress accomplished this purpose by “codify[ing] general common law tort principles and ... extend[ing] civil liability for acts of international terrorism to the full reaches of traditional tort law.” Boim v. Quranic Literacy Inst & Holy Land Found. for Relief and Dev. (Boim I), 291 F.3d 1000, 1010-11 (7th Cir. 2002) (per curiam). The result was a “powerfully broad” Act that “ ‘impos[es] ... liability at any point along the causal chain of terrorism’ ” in order to “ ‘interrupt, or at least imperil, the flow of money’ ” to terrorists. Id. at 1011 (quoting S. Rep. 102-342, at 22 (1992) (quotation marks, emphasis, and citations omitted); see also Statement of Senator Grassley, 136 Cong. Rec. S4568-01 (1990), at S4593 (“With the enactment of this legislation, we set an example to the world of how the United States legal system deals with terrorists. If terrorists have assets within our jurisdictional reach, American citizens will have the power to seize them”).
 
*66 Congress found it necessary to impose liability broadly because “foreign organizations that engage in terrorist activity are so tainted by their criminal conduct that any contribution to such an organization facilitates that conduct.” Antiterrorism and Effective Death Penalty Act of 1996, Pub. L. No. 104-132, § 301(a)(7), 110 Stat. 1214, 1247 (1996) (enacting 18 U.S.C. § 2339B) (emphasis added); see also Abecassis v. Wyatt, 785 F. Supp. 2d 614, 645 (S.D. Tex. 2011) (finding that “Congress’ clear intent” in the ATA was “to resist terrorism by cutting off the sources of funding to terrorist groups”). Such sources of funding include not only contributions to a terrorist organization, such as al-Qaeda, but also “funds [provided] ‘under the cloak of a humanitarian or charitable exercise ....’ ” Weiss v. Nat’l Westminster Bank PLC, 453 F. Supp. 2d 609, 626 (E.D.N.Y. 2006)). This is because “[m]oney is fungible” and, as a result, funding for nonviolent activities “frees up other resources within the organization that may be put to violent ends.” Holder v. Humanitarian Law Project, 130 S. Ct. 2705, 2725 (2010). Therefore, as recognized by the Supreme Court, “Congress’s use of the term ‘contribution’ is best read to reflect a determination that any form of material support furnished ‘to’ a *67 foreign terrorist organization should be barred, which is precisely what the material-support statute does.” Id.
 
To these ends, the ATA broadly provides a civil cause of action for “[a]ny national of the United States injured in his or her person, property, or business by reason of an act of international terrorism.” 18 U.S.C. § 2333(a). “International terrorism” encompasses “violent acts or acts dangerous to human life that are a violation of the criminal laws of the United States or of any State,” and that “appear to be intended ... to intimidate or coerce a civilian population” or “to affect the conduct of a government by mass destruction, assassination, or kidnapping.” Id. at § 2331(1). Such acts “transcend national boundaries in terms of the means by which they are accomplished ....” Id.
 
Defendants’ alleged provision of material support to al-Qaeda and entities assisting its efforts readily falls within the ATA’s scope. The district court did not dispute that plaintiffs adequately alleged that they were injured by acts of international terrorism. See SPA214 (Terrorist Attacks V); SPA1, 52 n.39 (Terrorist Attacks I). Those injuries arose from the terrorist attacks of September 11, 2001, which were attacks using means *68 that transcend borders and that were intended to intimidate a civilian population and to affect the conduct of the United States Government.
 
Thus, plaintiffs allege that defendants are both primarily and secondarily liable under the ATA, and the district court analyzed the claims under both theories. Compare SPA237 (Terrorist Attacks V) (finding that plaintiffs allege claims of primary liability under the ATA), with SPA52-53 (Terrorist Attacks I) (analyzing plaintiffs’ claims as alleging theories of secondary liability under the ATA). Primary liability is implicated because the plaintiffs’ injuries arose from violations of federal criminal laws that proscribe material support of terrorists, including through financing and through furthering the transborder attack of Americans within the United States. See 18 U.S.C. §§ 2339A, 2339B, 2339C, 2332B. Courts have recognized primary liability under the ATA for providing financing to terrorist organizations, even when the financing is channeled indirectly through intermediaries. See Boim v. Holy Land Found. for Relief and Dev. (Boim III), 549 F.3d 685, 701-02 (7th Cir. 2008) (en banc) (holding that “donors to terrorism [cannot] escape liability because terrorists and their supporters launder donations through a chain of intermediate organizations”); see also  *69 Wultz v. Islamic Republic of Iran, 755 F. Supp. 2d 1, 50-54 (D.D.C. 2010) (finding liability based on support provided to an agent of a terrorist organization). In addition, the organization receiving the support need only have a connection to terrorism. Cf. Humanitarian Law Project, 130 S. Ct. at 2717 (“Congress plainly spoke to the necessary mental state for a violation of § 2339B, and it chose knowledge about the organization’s connection to terrorism, not specific intent to further the organization’s terrorist activities”) (emphasis added); Boim III, 549 F.3d at 702 (finding that Donor A cannot escape ATA liability by providing funds “to innocent-appearing organization B which gives to innocent-appearing organization C which gives to [a terrorist organization]”).
 
Secondary liability under the ATA is present where defendants aid and abet those undertaking the terrorist act harming Americans. See, e.g., Boim I, 291 F.3d at 1010; Wyatt, 785 F. Supp. 2d at 645, 649; Wultz, 755 F. Supp. 2d at 54-57; Linde v. Arab Bank, PLC, 384 F. Supp. 2d 571, 582-85 (E.D.N.Y. 2005). In this case, plaintiffs allege that the defendants are secondarily liable under the ATA because their financing and other support activities aided and abetted al-Qaeda in terrorism.
 
*70 Under both theories of liability, an ATA claim may be predicated on the provision of support without plaintiffs having to establish that the defendants sought to advance any particular terrorist attack -- or even terrorist activities generally -- by the entities or persons receiving that support. See, e.g., Boim HI, 549 F.3d at 692-95 (finding that a donor need only know the character of the terrorist organization to be liable under the ATA); Wultz, 755 F. Supp. 2d at 40-41; Weiss, 453 F. Supp. 2d at 625 (“The requirement that the defendant have specifically intended to further terrorist activities finds no basis in the statute’s language”); Humanitarian Law Project, 130 S. Ct. at 2729 (money provided to a terrorist group for purportedly legitimate activities can be “redirected to funding the group’s violent activities”).
 
Here, with an exception applicable to discrete allegations regarding two defendants,109 the district court acknowledged that plaintiffs, if they could establish that defendants acted with the requisite mental state,110 adequately pled an ATA claim. See supra pp. 65-66 nn. 104-108. The district court also recognized that the ATA provides for recovery even if *71 the defendants did not anticipate or intend the September 11th Attacks, because it was well known during the 1990s that al-Qaeda sought to commit terrorist acts against the United States. SPA237-38 (Terrorist Attacks V); SPA20, 50 (Terrorist Attacks I). Thus, merely providing material support to al-Qaeda or a related entity with the requisite state of mind would suffice to make the defendants liable for injuries caused by al-Qaeda’s acts of international terrorism. See SPA237-39 (Terrorist Attacks V); SPA112-114 (SAMBA II); SPA110 (DMI-Kamel). This accords with the reasoning of other courts that have addressed ATA claims. See, e.g., Boim III, 549 F.3d at 693-94; Wultz, 755 F. Supp. 2d at 50-53; Weiss, 453 F. Supp. 2d at 627 n.15.
 
In sum, under a theory of secondary liability, the attacks are attributed to defendants based on their support for al-Qaeda and its affiliated entities and efforts to advance its objectives. Under a theory of primary liability, the defendants’ provision of support to al-Qaeda and its affiliated entities makes them directly responsible for the resulting, entirely foreseeable terrorist attacks.
 
                    *72 B. The District Court Erred In Finding that Plaintiffs Failed to Plead that Defendants Knowingly or Recklessly Provided Support for Terrorism
The district court faulted plaintiffs’ pleadings and dismissed their ATA claims against Al Rajhi Bank, Saudi American Bank, Saleh Abdullah Kamel, Dallah al Baraka, and DMI Trust principally based on a conclusion that plaintiffs failed to state a claim with respect to a single narrow element of the ATA cause of action: the defendants’ state of mind in the course of providing support to al-Qaeda. Under a theory of either primary or secondary ATA liability, a defendant is liable if it “either knows that the organization engages in [terrorist] acts or is deliberately indifferent to whether it does or not, meaning that one knows there is a substantial probability that the organization engages in terrorism but ... does not care.” Boim III, 549 F.3d at 693 (by analogy, giving “a small child a loaded gun would be a case of criminal recklessness and therefore satisfy the state of mind requirement”) (emphasis omitted); see also Wultz, 755 F. Supp. 2d at 50-51, 57 (finding that plaintiffs sufficiently pled that defendant had the requisite mental state to be both primarily and secondarily liable for providing banking services to a terrorist organization when plaintiffs alleged that the bank was warned by the Chinese government that its *73 services were being used by terrorists); Weiss, 453 F. Supp. 2d at 613-14 & n.4, 627 n.15 (finding that aiding and abetting liability was sufficiently pled based on allegation that defendant bank “had reason to know” that its clients were supporting terrorism). The district court held that plaintiffs’ pleadings did not adequately establish that defendants knew or had reason to know that their support, through financing and the provision of services, was being provided to persons and entities advancing al-Qaeda’s efforts. See SPA237-39 (Terrorist Attacks V); SPA112-114 (SAMBA II); SPA110 (DMI-Kamel); SPA57-58 (Terrorist Attacks I).
 
In determining that plaintiffs’ pleadings were conclusory and inadequate, the district court misapplied fundamental legal principles governing the assessment of a complaint and related pleadings upon a motion to dismiss. It also dramatically understated or disregarded the scope, detail, and logic of plaintiffs’ pleadings. Four principal errors infected the district court’s analysis: (1) the district court adopted and applied a heightened pleading standard for defendants accused of supporting terrorism, disregarding the well-established Rule 12 and Rule 8 standards and ignoring Congress’s intent regarding the ATA’s scope and operation; (2) the district court understated and overlooked plaintiffs’ *74 extensive pleading allegations regarding defendants’ knowing and reckless support for al-Qaeda, which were far from conclusory and provided extensive detail; (3) the district court failed to draw all reasonable inferences from plaintiffs’ pleadings taken as a whole, which sufficiently alleged and clearly supported an inference regarding defendants’ scienter through allegations of (a) direct support for the world’s most notorious terrorist organization, al-Qaeda, (b) the publicly-known terrorism associations of the charities and entities defendants supported, and (c) defendants’ proximity to, range, and pattern of dealings with entities essential to the al-Qaeda network; and (4) far from accepting the truth of the facts alleged by plaintiffs, the district court assessed and rejected certain evidence underlying plaintiffs’ claims, and considered and credited evidence to the contrary.
 
                    1. The District Court Applied an Incorrect, Heightened Standard In Evaluating Plaintiffs’ Pleadings.
The district court’s entire analysis of plaintiffs’ ATA allegations was tainted by its use of an erroneous legal standard to assess the adequacy of plaintiffs’ pleadings. A pleading need only provide a “short and plain statement of the claim showing that the pleader is entitled to relief.” Fed. R. Civ. P. 8(a)(2). “To survive a motion to dismiss, a complaint must *75 contain sufficient factual matter, accepted as true, to state a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 129 S. Ct. 1937, 1949 (2009) (quotation marks omitted). A claim is facially plausible if it includes “factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id.
 
The district court, however, applied a heightened standard of scrutiny to plaintiffs’ pleadings, one that has no basis in the Federal Rules and one that it created out of whole cloth exclusively for claims related to terrorism. The court found that due to “the extreme nature of the charges of terrorism, fairness requires extra-careful scrutiny of plaintiffs’ allegations as to any particular defendant, to ensure that he -- or it -- does indeed have fair notice of [the claims].” SPA55 (Terrorist Attacks I) (emphasis added, brackets in original, and quotation marks and citation omitted); accord SPA108 (DMI-Kamel); SPA100 (SAMBA I). Not only is this departure from the Federal Rules a fundamental legal error, but it also accounts for and explains why the district court disregarded and failed to credit plaintiffs’ extensive, entirely adequate pleadings, see infra Point I.B.2; failed to draw reasonable inferences from those pleadings, see infra *76 I.B.3; and declined to accept the truth of the facts alleged by plaintiffs, see infra Point LB.4.
 
Application of this heightened standard is especially misguided in light of Congress’s intent that the ATA reach just the conduct that plaintiffs allege. That is, “Congress[] clearly expressed [an] intent to cut off the flow of money to terrorists at every point along the causal chain of violence.” Boim I, 291 F.3d at 1021. Congress did this by “attach[ing] liability to all donations to foreign terrorist organizations regardless of the giver’s intent” because “foreign organizations that engage in terrorist activity are so tainted by their criminal conduct that any contribution to such an organization facilitates that conduct.” Id. at 1027. Moreover, Congress enacted Section 2339B, a criminal provision incorporated through the ATA, out of a “concern that terrorist organizations could raise funds ‘under the cloak of a humanitarian or charitable exercise.’ ” Weiss, 453 F. Supp. 2d at 626 (quoting H.R. Rep. 104-393, at 43 (1995)). That statute was designed to “ ‘severely restrict the ability of terrorist organizations to raise much needed funds for their terrorist acts within the United States.’ ” Id. Any effort to impose a heightened pleading standard upon terrorism-related *77 cases, as the district court did, thus “thwart[s] Congress’ clearly expressed intent.” Boim I, 291 F.3d at 1021.
 
                    2. The District Court Understated and Ignored Plaintiffs’ Extensive Pleadings Addressing Defendants’ Knowing and Reckless Support of Terrorism.
Although the district court acknowledged that plaintiffs had in certain respects pled that the defendants knowingly provided support to al-Qaeda,111 it radically understated the scope and detail surrounding those direct allegations. Far from presenting bare conclusions, plaintiffs abundantly provided defendants with notice of the basis for plaintiffs’ claims, including their assertion that defendants sought to advance al-Qaeda’s activities.
 
For each defendant, plaintiffs’ detailed allegations focused on the knowing or reckless nature of the provision of support to al-Qaeda. The particular allegations set forth below are in addition to plaintiffs’ extensive allegations regarding the broader context of al-Qaeda’s use and development of a financing network, the relation between the key financiers and financing mechanisms and al-Qaeda’s operations, and the integration of sources of financing into the broader social and ideological *78 network of persons and organizations that facilitated al-Qaeda’s activities. See supra pp. 29-60.
 
                    (a) Al Rajhi Bank
Al Rajhi Bank was founded in 1987 and “has a network of nearly 400 branch offices throughout Saudi Arabia and seventeen worldwide subsidiaries.” SPA55 (Terrorist Attacks I). Plaintiffs’ complaints contain numerous allegations that Al Rajhi Bank knowingly provided an extensive amount of material support to al-Qaeda front charities, including the International Islamic Relief Organization (“IIRO”), the Muslim World League (“MWL”), the World Association of Muslim Youth (“WAMY”), the Benevolent International Foundation (“BIF”), the Saudi Joint Relief Committee (“SJRC”), and Al Haramain Islamic Foundation (“Al Haramain”). See SPA55 (Terrorist Attacks I); JA1062-65, 1069-77, 3827-29. Its provision of material support included “knowingly and intentionally provid [ing] financial and bank account services” for al-Qaeda front charities and “September 11th hijacker Abdulaziz al-Omari.” JA1062-77, 1784, 2483, 3827-29.112 “Al Rajhi Bank has long known that the[se] *79 accounts ... were being used to solicit and transfer funds to terrorist organizations, including al Qaida.” JA3828. Through these bank accounts, Al Rajhi Bank “knowingly and intentionally ... facilitated [the] purchase of weapons and military equipment.” JA2483. Al Rajhi Bank also “knowingly and intentionally lent repeated material support to Al Qaeda,” including the front charities, “through, inter alia, the use of interstate and international faxes, telephones, wire transfers and transmissions, and mailings.” JA1064, 1784.
 
The complaints further allege that Al Rajhi Bank knowingly provided material support through its involvement in raising funds for al-Qaeda’s front charities, including by making direct donations to them, JA1068-73, 2483, guiding the donations of its customers, JA1069-70, cooperating with the charities to advertise the existence of their bank accounts, XXXXXX, and managing and accounting for donations, JA1071. Donations were often made as part of the Islamic duties of zakat and haram, which include an obligation by the donor “to determine” (i.e., know) that “the ultimate *80 recipients of these contributions fall within one of the categories prescribed in the Quaran ....” See infra p. 98-99; JA1068-73, 2483. Moreover, by advertising these accounts, Al Rajhi Bank “provid[ed] a mechanism to allow al Qaida’s supporters to deposit funds directly into those accounts.” JA3828.
 
Al Rajhi Bank’s operations are consistent with their support of al-Qaeda front charities. In 1999, Al Rajhi Bank was warned by United States government officials “that their financial systems were being manipulated or utilized to fund terrorist organizations such as Al Qaeda.” SPA55 (Terrorist Attacks I); JA 2584-86; infra pp. 93-95. “Despite these warnings, Al Rajhi failed to adopt even the most minimal standards, [which] resulted in the use of Al Rajhi as an instrument of terror ...” SPA55 (Terrorist Attacks I). By ignoring the most basic banking standards “designed to thwart the support of terrorist networks,” such as “anti-terrorist money laundering safeguards and ‘know your customer’ regulations,” Al Rajhi Bank willfully turned a blind eye towards the true nature of these charities. JA2483.
 
                    *81 (b) Saudi American Bank113
Plaintiffs’ complaints allege that Saudi American Bank has knowingly provided various forms of material support to al-Qaeda. For example, “Saudi American Bank knowingly provided material support and resources to al Qaida” by “finance [ing] many of the projects undertaken by Osama bin Laden and al Qaida in the Sudan during the years that the al Qaida leadership structure operated from that country ....” JA843-44, 3843. This included projects such as “the construction of major roads and the Port of Sudan airport.” JA3843.
 
Saudi American Bank is also alleged to have “knowingly provided financial services and other forms of material support to al Qaida.” JA3844. It did this by “maintain[ing] accounts for many of the ostensible charities that operate within al Qaida’s infrastructure, including MWL, WAMY, IRO and al Haramain” with “know[ledge] that [these] accounts ... were being used to solicit and transfer funds to terrorist organizations, including al  *82 Qaida.” JA843-44, 3843-44. “Saudi American Bank also serve[d] as the Saudi Arabia correspondent for many other banks within at Qaida’s infrastructure ....” JA843-44, 3844.
 
Plaintiffs further allege that “Saudi American Bank facilit[ated] al Qaida’s fundraising efforts” by “advertis[ing] the existence and numerical designation of the accounts it maintain[ed] for those charities throughout the Muslim world, and provid[ing] a mechanism to allow al Qaida supporters to deposit funds directly into those accounts.” JA3844. These actions were alleged to have been done “[i]n cooperation with the charities operating within al Qaida’s infrastructure ....” JA3844. Also, plaintiffs allege that in “2000, the Saudi American Bank participated in the fund raising campaign in Saudi Arabia for collecting donations to the ‘heroes of the Al Quds uprising’ (Intifada) by providing a bank account and facilities to receive donations for a committee of charity organizations including [WAMY], [IIRO,] and al Haramain Foundation.” JA844. In addition, plaintiffs allege that “from 1996 through 2001, the Saudi American Bank funneled money to and/or from the Spanish al Qaida cell.” JA4385.
 
                    *83 (c) Saleh Abdullah Kamel and Dallah al Baraka
Plaintiffs’ complaints allege that Saleh Abdullah Kamel, a Saudi businessman, has knowingly provided extensive material support to al-Qaeda, both individually and through his various business entities, including Dallah al Baraka. JA3869-70. For example, the complaints allege that Kamel personally “has made substantial contributions to many of the charities operating within al Qaeda’s infrastructure, with full knowledge that those funds would be used to support al Qaida’s operations and terrorist attacks.” JA3869-70. He is also alleged to have “long provided financial support and other forms of material support to terrorist organizations,” such as al-Qaeda. JA3162. Kamel’s role as a key financial supporter of al Qaeda’s is confirmed by his inclusion on the Golden Chain. JA3164; see infra pp. 109-10. One such contribution is alleged to have occurred in 1992, when Kamel donated $100,000 to Sanabil Al-Khair, the North American financial arm of the IIRO. JA3125. In addition, complaints allege that through personal investments, Kamel has provided financial support to publicly identified terrorist organizations, including by means of zakat donations requiring Kamel’s authorization. JA3173-74, 3193, 3200, 3869-70.
 
*84 The complaints further allege that “Kamel financed and developed Dallah al Baraka and its subsidiaries to operate as profitable banking and investment institutions and to serve as financial vehicles for transferring millions of dollars to Islamic militants around the world.” JA3162, 3869-70. In fact, plaintiffs allege that “[t]he practice and policy of Dallah Albaraka ... [was] to provide financial support and material assistance to international terrorist organizations including al Qaeda.” JA821. This support is alleged to have begun in 1982, when both Kamel and Dallah al Baraka “direct[ed] tens of millions of dollars in funds to at least 20 non-governmental organizations, including Osama bin Laden’s Mekhtab al Khidmat, the predecessor to al Qaeda ....” JA3162. Dallah al Baraka is also alleged to have “knowingly and intentionally lent material support to Al Qaeda through, inter alia, the use of interstate and international faxes, telephones, wire transfers and transmissions, and mailings.” JA1782, 3116. Additionally, Dallah al Baraka is alleged to have “knowingly and intentionally ... maintained and serviced bank accounts held by ... Al-Haramain whose funds were earmarked and transferred to Al Qaeda.” JA1783. Dallah al Baraka also is alleged to have “provided material support for terrorism,” by “consistently and constantly launder[ing] *85 money” and “engag[ing] in illegal transactions in monetary instruments.” R.1233, p. 3. Both Kamel and Dallah al Baraka are additionally alleged to have “continue[d] to maintain joint investments, shares, finances, and correspondent bank accounts with [Al Shamal Islamic Bank] even after it was widely known that the bank was materially supporting international terrorism and that Osama bin Laden was a major investor in the bank.” JA3128.
 
Plaintiffs further allege that beginning in 1983, Dallah al Baraka “facilitated jihad operations in the world [by] providing Osama bin Laden with financial infrastructures in Sudan ....” R.1233, Ex. A, p. 7. Dallah al Baraka also is alleged to have entered into “joint ‘symbiotic business’ investments” with “al Qaeda[’s] network of front companies, farms and factories in Sudan.” JA3135-36. And Kamel and Dallah al Baraka are alleged to have provided material support to the Spanish al-Qaeda cell, which directly funded the September 11, 2001, attacks, by permitting their use of an Al Baraka Bank Finance House in Turkey to transfer money to Osama bin Laden’s courier in Europe, Mohamed Bahaiah. JA3148.
 
In addition, plaintiffs’ complaints allege that Dallah al Baraka’s wholly-owned subsidiary and financial arm, Al Baraka Investment and *86 Development Company (“ABID Corp.”), often acting through subsidiaries over which ABID Corp. “exercised control and direction,” “has knowingly maintained accounts” for al-Qaeda front charities, including IIRO, MWL, WAMY, BIF, and al Haramain. JA1782, 3832; R.1233, Ex. A, p.6. ABID Corp. “has long known that the[se] accounts ... were used to solicit and transfer funds to terrorist organizations, including al Qaida.” JA3832. ABID has also “facilitate[d] al Qaida’s fundraising efforts by “advertis[ing] the existence and numerical designations of the accounts it maintains for th[e]se charities throughout the Muslim world, and provid[ing] a mechanism to allow al Qaida’s supporters to deposit funds directly into those accounts.” JA3832. These actions were done “[i]n cooperation” with the charities in question. JA3832. Plaintiffs’ complaints also allege that Kamel and ABID Corp. engaged in a scheme to purchase and export sesame products with businesses they “knew or should have known” were “owned and operated by Osama bin Laden.” JA3137.
 
                    (d) Dar-Al-Maal Al Islami (“DMI”) Trust
The complaints allege that as one of the central banking entities used by Saudi Arabia beginning in the early 1980s to “channel[l massive financial support for the spread of ... the radical brand of Islam at the heart *87 of the al Qaida ideology,” DMI Trust “directly and through its subsidiaries and affiliates, knowingly provided material support and resources to al Qaeda and/or affiliated individuals and entities.” JA3833, 4331. One such company is DMI Trust’s wholly owned and directly controlled subsidiary, DMI Administrative Services S.A. (“DMI S.A.”), which “puts into action the investments, strategies, distributions, and policies of the DMI Trust through direct assistance to al Qaeda.” JA4985; Companion Brief at Point I.B.2.(b)(iii).
 
Such support is alleged to have taken the form of “laundering money for al Qaeda, knowingly and intentionally providing financial services to al Qaeda (including mamtaining and servicing al Qaeda bank accounts and accounts used to fund and support al Qaeda), and/or facilitating weapons and military equipment purchases and money transfers for al Qaeda.” JA2569, 4986-87. DMI Trust is alleged to have utilized its “zakat [and haram] accounts ... to support al Qaeda ... [and] transferred money for Al Haramain.” JA2569-70, 2594-95. Plaintiffs additionally allege that “DMI [Trust] and its affiliated and subsidiary companies have known that many of the ostensible charities to which they channeled Zakat and Haraam funds were, in fact, fronts for al Qaeda [, including IIRO and MWL].” *88 JA4337. “Despite the actual knowledge that money contributed to these charities was being used to support terrorist activities, DMI and its affiliates and subsidiaries continued to send funds to these charities in the form of Zakat and Haraam contributions on their own behalf and on behalf of their investors, depositors and account holders.” JA4338.
 
Pleadings allege not only that DMI Trust acted through its wholly owned companies, but that those companies have “facilitated financial transactions for, and advertised, maintained and serviced accounts on behalf of, several of al Qaeda’s known charity fronts, including Al Haramain ..., [IIRO,] and [MWL].” JA4331. One such company that DMI Trust is alleged to have exercised “direct involvement” over is Faisal Islamic Bank of the Sudan. JA4331. Through this company and others, DMI Trust is alleged to have “entered into business partnerships with prominent al Qaeda supporters, such as the National Islamic Front, the fundamentalist regime which has ruled Sudan since 1989 and provided safe haven to Osama bin Laden and al Qaeda from 1991 through 1996.” JA4331. Specifically, Faisal Islamic Bank, and thus DMI Trust, is alleged to have provided loans and other support to the National Islamic Front and its prominent members. JA4332-33. Faisal Islamic Bank is also alleged to *89 have “actively participated in the collection of funds for certain of al Qaeda’s ‘charitable’ front organizations.” JA4337-38.
 
Another “wholly owned subsidiary, Faisal Finance,” is alleged to have “knowingly and intentionally” held and managed accounts for multiple al-Qaeda operatives, including Wa’el Julaidan and Yasin Al Kadi, who were both designated by the U.S. Department of Treasury as Specially Designated Global Terrorists. JA3723. Plaintiffs allege that in 1998, Al Kadi’s account was identified by “the FBI’s Counter Terrorism Task Force ... as being a source of funding for Hamas terrorist, Mohamed Saleh” and it “was one of the accounts frozen after September 11, 2001.” JA3823-24. Moreover, under DMI Trust’s control, Faisal Finance continued to provide these services even after Osama bin Laden publicly acknowledged his close ties to Julaidan in 1999. JA3723. Similarly, Tadamon Bank, another DMI Trust subsidiary, has “knowingly and intentionally lent repeated material support to Al Qaeda through” the provision of “financial and bank account services to several Al Qaeda operatives.” JA1789-90, 4335, 5915.
 
                    *90 3. The District Court Failed to Draw Reasonable Inferences From Plaintiffs’ Extensive Additional Pleadings Establishing Defendants’ Knowing and Reckless Support of Terrorism.
Further, plaintiffs presented extensive additional allegations that permitted -- indeed, compelled -- reasonable inferences that each defendant knew or recklessly disregarded whether the recipients of their funds and services were in fact advancing al-Qaeda’s efforts. Far from applying the rule that a court must draw “all reasonable inferences” in favor of the plaintiff when resolving a motion to dismiss, Matson v. Bd. of Educ. of the City Sch. Dist. of N.Y., 631 F.3d 57, 72 (2d Cir. 2011), the district court declined to draw even the most straightforward inferences about mental state from the extensive allegations of defendants’ actions directed toward al-Qaeda and its closest supporters. Plaintiffs’ allegations, taken as a whole, place defendants at the core of the network that supported al-Qaeda, including through direct provision of funds and services to al-Qaeda itself; extensive dealings with the most notorious and widely known charities, related organizations, and individuals who are prominently involved in global jihad and supporting al-Qaeda; and a pattern of dealing with and assisting the persons and entities most closely associated with al-Qaeda. An inference of mental state is almost always derived from *91 circumstantial evidence, and here that evidence pervasively and consistently points to the conclusion that defendants knew that their support advanced the efforts of al-Qaeda. Alternatively, at a minimum, plaintiffs’ allegations establish that only a person deliberately oblivious to the nature of the parties involved, which is the essence of recklessness, could have failed to understand that the alleged actions were supporting terrorism.
 
                    (a) Reasonable inference based on provision of support to al-Qaeda, a notorious terrorist organization.
The defendants are alleged to have “provided critical financial and logistical support to al Qaeda in relation to that terrorist organization’s global jihad.” JA3834, 3843-44, 3870, 4314, 4331. Defendants’ provision of material support to al-Qaeda came at a time when that terrorist organization was publicly, even notoriously, known to have declared its intent to “wage war with the United States.” JA3153, 3777. Moreover, al-Qaeda had taken credit for numerous terrorist attacks that were among the most highly publicized on the planet. As the district court noted, the terrorist organization had “publicly acknowledged responsibility for, such terrorist schemes as the 1993 bombing of the World Trade Center, the 1998 attack of the U.S. embassies in Kenya and Tanzania, and the 2000 attack of *92 the U.S.S. Cole in Yemen.” SPA20, 50 (Terrorist Attacks I) (quotation marks and citations omitted). In addition, President Bill Clinton signed an Executive Order on August 21, 1998, that “block[ed] the assets of Osama bin Laden and his terrorist cells, including Al Qaeda, as international terrorists.” JA1065-66.
 
These allegations and al-Qaeda’s notorious nature make plain the district court’s failure to draw a reasonable inference that the defendants had the requisite mental state of knowingly or recklessly advancing the efforts of a terrorist organization, where the pleadings contained detailed allegations that they provided material support to al-Qaeda. A stark example is the district court’s failure to infer that Al Rajhi Bank knew or had reason to know that it was providing financial services to al-Qaeda, despite plaintiffs’ allegations that United States government officials -- “William Weschler of the National Security Council and Richard Newcomb of the Office of Foreign Assets Control” -- warned Al Rajhi Bank in 1999 “that their financial systems were being manipulated or utilized to fund terrorist organizations such as Al Qaeda.” SPA55 (Terrorist Attacks I); JA1080-81. The district court simply noted that plainti ffs failed to allege “Al Rajhi Bank implemented ‘know your customer’ rules that Al Rajhi *93 failed to follow with respect to accounts held by the Defendant charities.” SPA57 (Terrorist Attacks I).
 
The district court’s holding is not only inconsistent with Wultz, 755 F. Supp. 2d at 50-5, where the court inferred that the Bank of China knowingly provided financial services to a terrorist organizations based on allegations that it had been issued a warning by a Chinese official, but also is inconsistent with its own later decision. There, plaintiffs alleged that Dubai Islamic Bank provided banking services to al-Qaeda, even as the United States government had provided warnings to the United Arab Emirates in 1999. SPA199-200 (Terrorist Attacks IV). These allegations, the district court concluded, “g[a]ve rise to the inference that [Dubai Islamic Bank] intentionally and knowingly assisted al Qaeda by providing banking services ....” Id. at 205. Similarly, the allegations against Al Rajhi Bank draw the reasonable inference that it, too, knowingly assisted al-Qaeda.
 
                    (b) Reasonable inference based on provision of support to charities known to be fronts for al-Qaeda.
It is also reasonable to infer defendants’ mental state based on allegations of material support to al-Qaeda front charities that were intimately involved in the al-Qaeda network and publicly known as such. The complaints allege that charities have “played a singularly important *94 role in al Qaida’s development and pursuit of its perverse ambitions ... [and] have served as the primary vehicle for raising, laundering and distributing funds on behalf of al Qaida from its inception.” JA3778. According to the United Nations, the main purpose of al-Qaeda front charities was “to raise and deliver funds to al-Qaida.” JA3778-79. And, as a 2002 independent commission on financing of international terrorism reported:
     [T]he most important source of al Qaeda’s money is its continuous fundraising efforts. Al Qaeda’s financial backbone was built from the foundation of charities .... In many communities, the zakat is often provided in cash to prominent, trusted community leaders or institutions, who then commingle and disperse donated moneys to persons and charities they determine to be worthy. These widely unregulated, seldom audited, and generally undocumented practices have allowed unscrupulous actors such as al Qaeda to access huge sums of money over the years. Today al Qaeda continues to raise funds from both direct solicitations of wealthy supporters and through retail charities. Some, whose donations go to al Qaeda, know full well the terrorist purposes to which their money will be put.
 
 
JA791.
 
The pleadings allege that it was widely and publicly known prior to September 11, 2001 that the charities supported by defendants were actually fronts for al-Qaeda. JA2483-84. For example, in September 1998, al Haramain was banned from Kenya for its involvements with the *95 bombing of United States embassies in both Kenya and Tanzania. JA2483. WAMY was identified as having been involved with the 1993 World Trade Center bombing. Id. MWL was known to have ties to a 1995 assassination attempt on Egyptian President Mubarak and the 1998 bombings of United States embassies. Id. IIRO was implicated for its “involvement with terrorist attacks and plots in Bosnia, the Philippines, Croatia, Kenya, India, Macedonia, Jordan, India, and the 1993 World Trade Center bombing ....” JA2483-84. SJRC “publicly discussed [its] involvement with terrorist attacks in Albania, Kosovo, Egypt, Tanzania and Kenya ....” JA2484. And, BIFs was publicly linked with “terrorist activities in Chechnya, the Sudan, Bosnia and the Philippines,” and its manager in Sudan had been arrested “under suspicion of ties to al Qaida.” Id.
 
The pleadings further allege that the relationship between these charities and al-Qaeda’s terrorism was widely known and publicly reported. Throughout the 1990s, numerous media reports and statements by government officials disclosed similar facts, including the terrorist activities of al Haramain, IIRO, and WAMY. JA 2596-97, 4337-38, 7891-94. For example, a major Egyptian newspaper, Rose Al Yusuf, reported in late 1992 “that the IIRO and the Bin Laden Organization in Egypt recruited and *96 sponsored more than 700 Arab operatives to travel to Afghanistan to train as jihadist terrorists.” JA2596. International media reported “that the Cairo office of the IIRO was managed by the bin Laden family and Mohamad Showki Al Istanbul, who was sentenced to death in Egypt for his Islamic extremist activities.” Id. Another newspaper reported that “[t]he IIRO was shut down by Egyptian authorities later in 1993 or early 1994 as a result of the charity’s links to Osama Bin Laden.” Id. An article in Rose Al Yusuf provided:
     Working with Palestinian Islamist Shaykh Abdallah Azzam, Bin-Ladin set up the ‘Jihad and Relief” guesthouse in Peshawar to receive volunteers who would arrive after a short stop in the al-Ansar guesthouse in Jeddah. The route of this process passed through the unlicensed Cairo office of the [MWL], directed by Dr. Abdallah Umar Nasif.
 
 
JA2596-97. In addition, public testimony from a high-level al-Qaeda operative prior to September 11, 2001, “described how Osama Bin Laden’s brother-in-law, convicted terrorist and IIRO employee, Jamal Khalifa, opened a [MWL] office in Pakistan for the use of the founders of al Qaeda to recruit, train and equip al Qaeda terrorists.” JA2597.
 
Moreover, it is entirely reasonable to conclude that the defendants were aware of these facts based on their obligation under the Koran to *97 inquire into the source of their zakat and haram donations, many of which went to al-Qaeda front charities. See supra 47-48, 50-51, 81-82, 85, 89-90, 96; JA1070-71. That is, “[t]he Quran requires every Muslim, individuals and corporations, to give Zakat for specific charitable purposes identified in the Quaran.” JA1062. Muslims are also required to donate their haram income, which is money derived from sources such as earned interest or “impure activities such as gambling or the sale of liquor.” JA1063-64. To ensure that their zakat and haram contributions “satisfy their religious obligations under Islam,” entities making the contributions are “required to determine that the ultimate recipients ... fall within one of the categories prescribed in the Quran ....” JA1070.
 
It is commonplace for courts to infer a defendant’s mental state from surrounding facts when analyzing a Rule 12(b)(6) motion to dismiss. See, e.g., In re Chiquita Brands Int’l, Inc., 690 F. Supp. 2d 1296, 1310 (S.D. Fla. 2010) (“ ‘knowledge may be inferred from circumstantial evidence’ ”) (quoting Schneberger v. Wheeler, 859 F.2d 1477, 1480 (11th Cir. 1988)); Foster v. Auburn Univ., No. 11-CV-503, 2011 U.S. Dist. LEXIS 141056, at *11-12 (M.D. Ala. Dec. 8, 2011) (finding that factual allegations gave rise to reasonable inference that defendant engaged in intentional conduct); Med- *98 Sys. v. Masterson Mktg., No. 11-CV-695, 2011 U.S. Dist. LEXIS 135216, at *19-20 (S.D. Cal. Nov. 23, 2011) (same); U.S. Bank Nat’l Ass’n v. Verizon Commc’ns, Inc., No. 10-CV-1842, 2011 U.S. Dist. LEXIS 106657, at *12-16 (N.D. Tex. Sept. 19, 2011) (same); Redding v. Edwards, 569 F. Supp. 2d 129, 132 (D.D.C. 2008) (same); Almog v. Arab Bank, PLC, 471 F. Supp. 2d 257, 291 (E.D.N.Y. 2007) (same). Even in the context of criminal prosecutions under Sections 2339A and 2339B, courts have held it proper to infer a defendant’s mental state based on circumstantial evidence. See, e.g., United States v. El-Mezain, No. 09-1560, 2011 U.S. App. LEXIS 24216 (5th Cir. Dec. 7, 2011) (finding that “it was logical for the jury to conclude that the defendants’ inten[ded] ... to support Hamas” as “the evidence strongly supported the inference that the defendants were connected to Hamas”); United States v. Augustin, 661 F.3d 1105, 1121 n.7 (11th Cir. 2011) (finding that “there is ample circumstantial evidence of [the defendant’s] knowledge of Al Qaeda and its terrorist activities”); United States v. Kassir, No. 09-CR-356, 2009 U.S. Dist. LEXIS 83075, at *21-22 (S.D.N.Y. Sept. 11, 2009) (finding that evidence “allowed the jury to infer that [the defendant] intended the jihad training to benefit al Qaeda”).
 
*99 An inference that the defendants possessed the requisite mental state is particularly reasonable where, as here, the plaintiffs allege that the charities supported by the defendants were publicly known to have been involved in terrorist activities and to be affiliated with al-Qaeda. See Wyatt, 785 F. Supp. 2d at 647-48; see also Goldberg v. UBS AG, 660 F. Supp. 2d 410, 428-29 (E.D.N.Y. 2009) (finding that plaintiffs had “sufficiently pled that the defendant consciously disregarded the fact that it was supporting a terrorist organization” when various forms of public information suggested “that [the recipient] was funneling money to terrorist organizations”); Strauss v. Credit Lyonnais, S.A., No. CV-06-0702, 2006 U.S. Dist. LEXIS 72649, at *47-49 (E.D.N.Y. Oct. 5, 2006) (drawing a reasonable inference that a bank “had reason to know” one of its customers was a terrorist group based on “public investigations of” the group and discussions within the press). In Wyatt, the district court drew upon public awareness that Iraq supported suicide bombers in Israel to “infer that ... the defendants knew the[ir kickbacks to Iraq] would be used for that purpose.” 785 F. Supp. 2d at 647-48. And in Weiss, the district court inferred that defendants “had reason to know the activities of its clients because of its legal and self-imposed obligations to know its customers.” *100 453 F. Supp. 2d at 627 n.15. Here, the facts alleged establish a general public awareness that the front charities supported by the defendants had been involved in acts of terrorism and actively aided al-Qaeda, and that the defendants had an obligation to know the source of their donations. These allegations give rise to a reasonable inference that defendants possessed the requisite mental state under the ATA, namely, that they knew or had reason to know the entities they supported were fronts for al-Qaeda.
 
                    (c) Reasonable inference based on defendants’ extensive relationship with the al-Qaeda network.
The plaintiffs also provided sufficient allegations connecting the defendants to the center of al-Qaeda’s network of terrorism, and individuals in the midst of al-Qaeda’s network are more likely to be part of al-Qaeda and at least well placed to know the nature of its activities. See Al-Adahi v. Obama, 613 F.3d 1102, 1109-10 (D.C. Cir. 2010) (finding that petitioner’s “close connection to the al-Qaida leadership ... strengthened the probability that he was part of al-Qaida”), cert. denied, 131 S. Ct. 1001 (2011). As such, it is entirely reasonable to infer, based on plaintiffs’ allegations as a whole and in considering a motion to dismiss, that defendants provided material support to al-Qaeda with the requisite knowledge. See id. at 1105 (finding that a district court erred by analyzing *101 evidence individually, as opposed to holistically, to determine whether the petitioner was a member of al-Qaida, because certain patterns of behavior increase the likelihood that an individual is a member of the terrorist organization); see also Salahi v. Obama, 625 F.3d 745, 753 (D.C. Cir. 2010) (the court “must view the evidence collectively rather than in isolation”). As the quantity and significance of a defendant’s dealings and contacts with notorious members and supporters of al-Qaeda increase, it becomes at least reasonable to conclude that a defendant actually knows who his associates are. Plaintiffs’ allegations far exceed that threshold.
 
For example, the pleadings allege that the chairman and managing director of Al Rajhi Bank, Suleiman Abdel Aziz Al Rajhi, was a member of IIRO’s board of directors and “directly participate[d] in the management, funding and operation of ... MWL and IIRO.” JA3827-28. The pleadings also allege that while Abdul Aziz Al-Khereiji served as an executive on Al Rajhi Bank’s board of directors, he “was also a Director of a terrorist front, Muwaffaq Limited.” JA1078-79. In addition, plaintiffs allege that “[d]irectors and advisory members of Al Rajhi [Bank] and its Shariah Boards share directorships and advisory positions with [al-Qaeda front] charities ....” JA1079. One such individual was alleged to be Sheik *102 Abdallah bin Abd-al Rahman al Basam, who “simultaneously served as chairman of the Sharia Supervisory Committee in the IIRO, and as a member of the Sharia Committee of the al Rajhi Bank. He was also a member of the Holy Qura Committee of the [MWL].” JA2484-85.
 
Plaintiffs’ allegations were corroborated by The Wall Street Journal report of the extensive contacts between Al Rajhi Bank and al-Qaeda:
     Islamic extremists have used Al-Rajhi Banking & Investment Corporation (ARABIC) since at least the mid-1990s as a conduit for terrorist transactions, probably because they find the bank’s vast network and adherence to Islamic principles both convenient and ideologically sound. Senior al-Rajhi family members have long supported Islamic extremists and probably know that terrorists use their bank. Reporting indicates that senior al-Rajhi family members control the bank’s most important decisions and that ARABIC’S principle [sic] managers answer directly to Suleiman. The al-Rajhis know they are under scrutiny and have moved to conceal their activities from financial regulatory authorities.
 
 
JA7882.114 Based on these allegations, Al Rajhi Bank had reason to know of the charities’ “extensive sponsorship of al Qaida’s operations, and consequently that the accounts maintained by Al Rajhi Bank on behalf of *103 those organizations were being used to channel funds to al Qaida.” JA3828.
 
Plaintiffs made further allegations connecting the Al Rajhi family, “which owns and controls Al Rajhi Bank,” to al-Qaeda, including that they have ties to Osama bin Laden’s personal secretary, are major donors to the SAAR network, and are closely associated with wealthy donors to Osama bin Laden identified on the Golden Chain. SPA56 (Terrorist Attacks I); JA1081-85; Companion Brief at Point LB.2(c). The district court found such allegations to be insufficient because plaintiffs did not also provide “allegation[s] that the family members were acting in furtherance of Al Rajhi Bank business.” SPA57 (Terrorist Attacks I). The district court missed the point entirely, though, in focusing on the family members’ actions and whether they furthered the bank’s business. As the D.C. Circuit found in Al-Adahi, these allegations of the family members’ affiliations and patterns of behavior paint a mosaic revealing intimate involvement with al-Qaeda. As a result, these allegations support a reasonable inference that defendants’ provision of material support to al-Qaeda was done either knowingly or recklessly.
 
*104 The district court made the same error in finding insufficient allegations that Al Rajhi Bank provided material support to Hamas and other terrorists, including through provision of funds to Tulkarm Charity Committee, a known front for Hamas. SPA56-57 (Terrorist Attacks I); JA1077-79. Plaintiffs also alleged that Al Rajhi Bank hosted its website with Infocom, a Texas-based company owned and operated by Mousa Marzook, a Hamas leader and designated terrorist. SPA56 (Terrorist Attacks I); JA1077-78. Infocom has provided funding to Hamas, and Al Rajhi Bank has made transfers from its accounts to Marzook and Infocom. SPA56 (Terrorist Attacks I). The district court found these allegations to be insufficient to support the ATA claim on the ground that “[p]laintiffs have not alleged any relationship between Hamas and al Qaeda or the terrorist attacks of September 11.” Id. at 57. Again, this ignores that such allegations provide greater support for an inference that Al Rajhi Bank had the requisite mental state when providing material support to al-Qaeda, because associates of terrorists tend to be aware of and involved in numerous activities of terrorists.
 
Allegations against the other defendants provide support for the same inference. The pleadings allege that Saudi American Bank has a close *105 relationship with the Saudi Bin Laden family and “directly and materially supported Hamas, Palestinian Islamic Jihad, and other terrorist groups in that region” by “participat[ing] in the scheme to fund terrorists in Gaza and the West Bank.” Id. at 58; JA3089.
 
DMI Trust is alleged to have served as one of the central banking entities that, beginning in the early 1980s, Saudi Arabia used to “channel[] massive financial support for the spread of Wahhabism, the radical brand of Islam at the heart of the al Qaida ideology” by “provid[ing] material support and resources to al Qaeda ....” JA3833, 4331. The pleadings also allege that DMI Trust has extensive relationships with al-Qaeda and its closest operatives. For example, DMI Trust is the parent company of Islamic Investment Company of the Gulf, which is the parent of Al Shamal Bank. JA2570. Osama bin Laden helped establish Al Shamal Bank in 1991 by providing capital of $50 million, and it has since held accounts for numerous al-Qaeda operatives. JA2570-71. Adel Baterjee, a wealthy Saudi businessman and close associate of Osama bin Laden, is the chairman of Al Shamal Bank. JA2587. All of DMI Trust’s entities are chaired by Price Mohamed al-Faisal al-Saud, a known collaborator of al-Qaeda, who has “engaged in the sponsorship of international terrorism through [DMI *106 Trust], the Faisal Islamic Bank and Al Shamal Bank.” JA902, 2584. DMI S.A., the wholly owned and controlled subsidiary of DMI Trust, owns 100% of Islamic Investment Company of the Gulf, for which Mohamed al-Faisal al-Saud was the Chairman and Haydar Mohamed Bin Laden, the brother of Osama bin Laden, was a Director, and which is the main shareholder of Faisal Islamic Bank (Sudan). JA832, 2562. DMI Trust also appointed Hassan Abdallah Al Turabi, who has “embrace[d] an ideology of violence ...[,] promote[d] violent jihad ...[,] and encouraged radical Islamic terrorist groups such as al Qaeda” as a supervising Board of Director. JA2576-82. Youssef al-Karadawi, “the spiritual leader of the Muslim Brotherhood who promotes the ... philosophy of jihad” and “has been barred from entering the [United States] since November 1999 for his alleged support of terrorism and affiliations with al-Qaeda associates[,]” has served as a “member of the Religious Board of DMI Trust ....” JA2590-92.
 
In addition, the pleadings allege that Saleh Abdullah Kamel “established Dallah Al Baraka as a central house for Islamic terrorism when al Qaeda first started carrying out attacks against the United States.” JA4314. Saleh Abdullah Kamel visited Sudan in 1991 with Saudi officials *107 and businessmen -- including Yassin Al-Qadi, who was named as a Specially Designated Global Terrorist on October 12, 2001 -- and entered into “symbiotic business” investments with Osama bin Laden’s entities and the government of Sudan. JA3132. Saleh Abdullah Kamel was also listed as a board member for IIRO’s office in Washington, DC, and he was reported to have “major investments” in Bank Al-Taqwa, a notorious Specially Designated Global Terrorist. JA3125-26, 3146. Dallah al Baraka “is a shareholder of Aqsa Islamic Bank, a bank that Israel has refused to approve, ‘citing obvious ties with known terrorists.’ ” SPA60 (Terrorist Attacks I).
 
Both Saleh Abdullah Kamel and Al Rajhi Bank’s chairman and managing director, Suleiman Abdel Aziz al Rajhi, are alleged to have been identified in the “Golden Chain” document as one of al-Qaeda’s principal financiers. JA3164, 3866-67, 3869-70; see also supra pp. 56-60. United States intelligence agencies concluded that the seized materials were authentic al-Qaeda documents that chronicle the formation of al-Qaeda, detail its financial and organizational structure, and identify al-Qaeda’s most important financial benefactors and the individuals responsible for coordinating their contributions. See supra at pp. 54-55 nn.85-86. Jamal al *108 Fadl, a senior al-Qaeda official who defected and became a cooperating witness for the United States, has authenticated the Golden Chain document. See supra at 55 n.86. The Treasury Department has used inclusion on that list as a basis for designating individuals as terrorist sponsors and for freezing their assets under Executive Order 13224. Id. The Golden Chain has been relied upon by the United States as an exhibit in multiple criminal cases. See supra at pp. 54-55 nn.85-86. And, the 9/11 Commission’s Final Report also relied upon the Golden Chain. See supra pp. 25-26 & n.8.
 
These allegations, taken together, detail an extensive relationship between the defendants and al-Qaeda, giving rise to a reasonable inference that the defendants’ provision of material support to al-Qaeda was knowing or, at the very least, reckless. The reasonableness of this inference is supported by the D.C. Circuit’s judicial review of habeas petitions brought on behalf of Guantanamo Bay detainees. See, e.g., Al Alwi v. Obama, 653 F.3d 11 (D.C. Cir. 2011); Uthman v. Obama, 637 F.3d 400 (D.C. Cir. 2011); Al-Adahi, 613 F.3d at 1102; Al-Bihani v. Obama, 590 F.3d 866 (D.C. Cir. 2010), cert. denied, 131 S. Ct. 1814 (2011). In order to have a basis to continue to detain a petitioner, the United States has been required to *109 prove that a detainee was “more likely than not ... part of, or substantially supported, Taliban or al-Qaida forces or associated forces ....” Al Alwi, 653 F.3d at 15. This inquiry is fact specific and has required the court to infer, based on circumstantial evidence, a petitioner’s state of mind -- whether he was “part of” al-Qaeda. See, e.g., id. at 17-18; Uthman, 637 F.3d at 407 (“[I]t remains possible that Uthman was innocently going about his business ... [but] the far more likely explanation for the plethora of damning circumstantial evidence is that he was part of al Qaeda”); Salahi, 625 F.3d at 751-52 (“[T]he determination of whether an individual is ‘part of al-Qaida must be made on a case-by-case basis by using a functional rather than a formal approach and by focusing upon the actions of the individual in relation to the organization” (quotation marks and citations omitted)).
 
The standard employed by the D.C. Circuit is substantially more rigorous than that required in the present case, both because the United States must establish its case by a preponderance of evidence (rather than the pre-discovery, prima facie showing required here), and because the issue is whether a defendant actually served as “part of” al-Qaeda (rather than whether it simply provided knowing support to al-Qaeda). Compare Al Alwi, 653 F.3d at 15 (government must put forward evidence proving *110 that the petitioner was “more likely than not ... part of, or substantially supported, ... al-Qaida”), with Iqbal, 129 S. Ct. at 1949 (plaintiffs’ allegations need merely “allow [] the court to draw the reasonable inference that the defendant is liable for the misconduct alleged”), and Boim III, 549 F.3d at 693 (required mental state under the ATA is whether defendant “kn[ew] that the organization” to which he provided material support “engage[d] in [terrorist] acts or [wa]s deliberately indifferent to whether it d[id]”).
 
Even applying this more stringent standard, the D.C. Circuit has consistently found that habeas petitioners were “part of” al-Qaeda. See Al Alwi, 653 F.3d at 18 (collecting cases). For example, in Al-Bihani, the court held that an individual’s presence at “Al Qaeda training camps in Afghanistan” or “Al Qaeda guesthouses ... overwhelmingly, if not definitely, justif[ies] the government’s detention ....” 590 F.3d at 873 n.2. In Uthman, the court looked at a variety of factors, including that the petitioner had attended a religious school where al-Qaeda had recruited fighters and “traveled to Afghanistan along a route used by al Qaeda recruits,” to reach the same conclusion. 637 F.3d at 403-04. And, on numerous occasions, the D.C. Circuit has reproached the district court for *111 its failure to draw reasonable inferences from a petitioner’s contacts with those associated with al-Qaeda. See, e.g., Al Adahi, 613 F.3d at 1109-10 (finding that the district court “committed ... the fallacy of the possible proof” in declining to infer that the petitioner had a close relationship with al-Qaeda’s leadership based on the possibility that the evidence showing his deep knowledge of al-Qaeda’s leadership could have been learned some other way); Salahi, 625 F.3d at 753 (finding that petitioner’s limited relationships with al-Qaeda operatives did not “independently ... prove that he was ‘part of’ al-Qaida, those connections make it more likely that [he] was a member of the organization ... and thus remain relevant to the question of whether he is detainable”).
 
Thus, even in that more rigorous context, the D.C. Circuit has squarely rejected the approach taken by the district court here (ignoring the context of a defendant’s alleged actions and examining each allegation in isolation). For example, the habeas cases repeatedly find that an inference of al-Qaeda membership may be drawn from a pattern of dealing with persons associated with al-Qaeda or from sharing characteristics with those persons. See Uthman, 637 F.3d at 407 (circumstantial evidence, in the form of repeated dealings with al-Qaeda, sufficient to establish membership) *112 (collecting cases). As the D.C. Circuit held, such “evidence tend[s] to show [the detainee’s] close relationship with these men and thus strengthen[s] the probability that he was part of al-Qaida.” Al Adahi, 613 F.3d at 1109; accord Uthman, 637 F.3d at 407 (“[detainee’s] actions and recurrent entanglement with al Qaeda show that he more likely than not was part of al Qaeda”). Just as clearly, the D.C. Circuit has recognized that courts “must view the evidence collectively rather than in isolation.” Salahi, 625 F.3d at 753. “Merely because a particular piece of evidence is insufficient, standing alone, to prove a particular point does not mean that the evidence ‘may be tossed aside and the next [piece of evidence] may be evaluated as if the first did not exist.’ ” Id. (quoting Al-Adahi, 613 F.3d at 1105) (brackets in original).
 
                    4. The District Court Vailed to Accept the Truth of the Tacts Alleged.
In considering a motion to dismiss, courts are of course under an obligation to “assume the[] veracity” of the plaintiffs’ factual allegations and to view them “in a light most favorable to the plaintiff.” Iqbal, 129 S. Ct. at 1950; Matson, 631 F.3d at 72. In addressing crucial allegations bearing directly on defendants’ state of mind, the district court failed to follow these basic principles.
 
*113 For example, when analyzing the claims against Al Rajhi Bank, the district court rejected the truth of plaintiffs’ allegations, and instead, accepted Al Rajhi Bank’s version of events. After recounting plaintiffs’ allegation that Al Rajhi Bank had a duty to inquire into the recipients of their zakat donations, the district court noted that Al Rajhi Bank “submits it did not have a duty, or a right, to inspect the ... charities’ financial transactions to ascertain the ultimate destination of its donations.” SPA56 (Terrorist Attacks I). The district court continued, “Al Rajhi Bank contends it had a legal and religious duty to make its charitable donations and any terrorist activity by the recipient charities was unknown to Al Rajhi Bank.” Id. The district court then concluded that the “[p]laintiffs do not offer facts to support their conclusions that Al Rajhi Bank had to know that ... [the recipient] charities ... were supporting terrorism.” Id. at 57. To reach this finding, the district court necessarily ignored or declined to assume the truth of plaintiffs’ express allegation that Al Rajhi Bank was “required to determine that the ultimate recipients of these contributions fall within one of the categories prescribed in the Quran for recipients of Zakat.” Id. At the pleading stage, the court’s reasoning is error. See Iqbal, 129 S. Ct. at 1950; Matson, 631 F.3d at 72.
 
*114 The district court also failed to follow the standards that govern review of a motion to dismiss when it rejected “as having no evidentiary value” the plaintiffs’ allegations that Saleh Abdullah Kamel and Al Rajhi Bank’s chairman and managing director, Suleiman Abdel Aziz al Rajhi, were listed on the Golden Chain. SPA247 (Terrorist Attacks V); accord SPA110 (DMI-Kamel); SPA42 (Terrorist Attacks I).
 
This finding is not only an impermissible rejection of plaintiffs’ allegations concerning the Golden Chain, but also is inconsistent with the findings of other courts and the Executive branch. For example, the Golden Chain -- along with other documents discovered in the same raid -- was relied upon by the Government in an Evidentiary Proffer of al-Qaeda sponsor, Enaam Arnaout, and also referenced and used as a resource in Arnaout’s sentencing hearing. See supra pp. 54-55 nn.85-86. It was cited in the 9/11 Commission’s Final Report in July 2004, see supra pp. 25-26 & n.8, and the CRS has cited it in numerous reports, see supra p. 56. The 9/11 Commission Monograph on Terrorism Financing cites to “a group of wealthy donors from the Persian Gulf region known as the “Golden Chain,” which provided support to ... Usama Bin Ladin.” See supra p. 55 & n.87. The 9/11 Monograph continues:
     *115 The material seized [in Bosnia] included many documents never before seen by U.S. officials, such as the actual minutes of al Qaeda meetings, the al Qaeda oath, al Qaeda organizational charges, and the “Golden Chain” list of wealthy donors to the Afghan mujahideen ....
 
 
See supra p. 56 n.89. The Golden Chain has also been used by the U.S. Treasury Department in designating persons as Specially Designated Global Terrorists. See supra p. 55 n.86.
 
The district court committed further error by failing to credit plaintiffs’ allegations that DMI Trust, Dallah al Baraka, and Saleh Abdullah Kamel controlled their subsidiaries that provided material support to al-Qaeda. See SPA245, 247 (Terrorist Attacks V); SPA109 (DMI-Kamel); SPA60 (Terrorist Attacks I). A plaintiff sufficiently pleads an ATA claim by alleging that the defendant provided material support to terrorists through an entity that the defendant controlled. See Wyatt, 785 F. Supp. 2d at 648 (finding that plaintiffs stated an ATA claim where they alleged that company controlled intermediary through which it provided material support). As the D.C. Circuit explained, “[w]hen one entity so dominates and controls another that they must be considered principal and agent, it is appropriate, under [the ATA], to look past their separate juridical identities *116 and to treat them as aliases.” Nat’l Council of Resistance of Iran v. Dep’t of State, 373 F.3d 152, 157 (D.C. Cir. 2004).
 
The plaintiffs’ allegations met this standard. For example, plaintiffs allege that DMI Trust and DMI S.A. “directly participate in the oversight and management of DMI Trust’s subsidiary and associate entities.” JA4329. In addition, DMI Administrative Services, S.A. is alleged to be “a wholly owned subsidiary directly controlled by DMI Trust,” JA4330, and DMI Trust is alleged to have “direct involvement” over Faisal Islamic Bank, JA4331. Plaintiffs also allege that Kamel “headed” Dallah al Baraka and its wholly-owned subsidiary, ABID Corp., which “exercised control and direction” over numerous subsidiaries. JA1782, 3122, 3832.
 
                    C. The District Court Incorrectly Disregarded Extensive Allegations of Support to al-Qaeda by Defendants Dallah al Baraka and Saleh Abdullah Kamel in the Early to Mid 1990s
The district court also found that the plaintiffs had not pled “the requisite causal connection” for their ATA claims against Dallah al Baraka and Saleh Abdullah Kamel because “the alleged provision of material support” to “Osama bin Laden ... during the early 1990s ... is too remote from the 9/11 terrorist attacks ....” SPA247 (Terrorist Attacks V). This conclusion resulted from a legal error regarding the applicable pleading *117 standard and a legal error regarding the inferences that may reasonably be drawn about support for terrorism, especially against the backdrop of Congress’ intended scope of the ATA. The court also made a critical factual error that necessitates correction.
 
First, the district court incorrectly applied a heightened pleading standard regarding this specific issue. To establish causation when an undefined period of time separates the material support alleged from the terrorist attack, the district court required that the plaintiffs plead:
     sufficient factual allegations of a connection between the material support provided and the acts of terrorism that caused plaintiffs’ injuries, such that a reasonable trier of fact could conclude that it was more likely than not that the support provided by the defendant assisted the terrorists in the commission of the terrorist act.
 
 
Id. at 239 (emphasis added). The court’s “more likely than not” and “reasonable trier of fact” requirements are inconsistent with Iqbal/ Twombly, which only require that a plaintiff plead facts that permit “the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Iqbal, 129 S. Ct. at 1949. The district court’s standard therefore imposed a much greater burden on the plaintiffs than is permitted at this stage of the proceeding.
 
*118 In addition, the inference that support for al-Qaeda in the early and mid 1990s contributed to al-Qaeda’s capabilities and terrorist activities only a few years later, in 2001, is entirely reasonable -- indeed, any other conclusion is unreasonable. Plaintiffs’ allegation, which must at this stage be taken as true, was that support in the years leading up to the September 11 attacks, including support for al-Qaeda in Sudan, was essential to al-Qaeda’s ability to achieve the global scale and capability necessary to mount a significant transborder attack. See JA3777-78. In particular, plaintiffs alleged that support during that crucial period enabled al-Qaeda to expand its footprint, train terrorists, plot and plan acts of terror, and carry out such acts around the world. JA798-800, 823, 843-44, 3783, 3836, 3871; cf. SPA152 (Terrorist Attacks IV) (as the district court elsewhere acknowledged, “[s]ince its inception in the late 1980’s, al-Qaeda has relied on well-placed financial facilitators and logistical sponsors to raise, manage and distribute money and resources, enabling it to grow rapidly into a formidable international terrorist network”).
 
Imposing ATA liability on defendants who provide this crucial formative support for a terrorist organization is clearly consistent with Congress’ intent, see supra pp. 66-73, and consistent with the nature of *119 how terrorist groups grow and become capable of undertaking attacks which, like the September 11 attacks, often take years of planning and development. See, e.g., 9/11 Commission Final Report p. 48. Thus, as the Seventh Circuit has held en banc, the ATA is predicated on the assumption that “[t]errorism campaigns often last for many decades .... Seed money for terrorism can sprout acts of violence long after the investment.” Boim III, 549 F.3d at 700. The court went so far as to conclude that, as a general matter, imposing liability upon “someone who with the requisite state of mind contributed to a terrorist organization in 1995 that killed an American abroad in 2045 ... would not be as outlandish, given the character of terrorism, as one might think.” Id. at 699-700. Here, of course, a much more direct connection of a few years exists between defendants’ acts that supported the development of what became the world’s most extensive and capable global terrorist organization and that group’s execution of its most sophisticated and deadly operation.
 
Lastly, the district court found that “[t]he United States had not even been targeted by al Qaeda” when “defendants provided [Osama bin Laden] with funding” while “in Sudan during the early 1990’s.” SPA247 (Terrorist Attacks V). This finding is blatantly incorrect. See supra pp. 28- *120 29. Osama bin Laden had been openly “singl[ing] out the United States for attack” “since 1992.” 9-11 Commission Final Report, at 48. “Plans to attack the United States were developed with unwavering single-mindedness throughout the 1990s.” Id.
 
                    II. The District Court Improperly Dismissed The Alien Tort Statute Claims Because The Statute Encompasses Claims Based On Acts Related To International Terrorism
The district court dismissed the Alien Tort Statute (“ATS”) claims against a handful of defendants because it thought plaintiffs were required to, but did not, plead “factual allegations [to] support a reasonable inference that the defendant[s] purposefully aided and abetted, conspired with, or materially supported al Qaeda in the commission of an act of terrorism involving the hijacking of a commercial airplane.” SPA233 (Terrorist Attacks V). That holding is based on a mistaken assumption that the ATS authorizes, or plaintiffs alleged, only tort claims based on the hijacking of a commercial airplane in violation of international law. Neither the ATS nor plaintiffs’ complaints are so limited. Instead, the ATS permits the federal courts to adjudicate a civil action “by an alien for a tort only, committed in violation of the laws of nations or a treaty of the United States.” 28 U.S.C. § 1350. As explained below, the “laws of nations” *121 prohibit acts of international terrorism, including the provision of material support for terrorism, and is not so narrowly focused on hijacking commercial airplanes. See infra at Points II.B & C. And, plaintiffs adequately pled facts that readily support a reasonable inference that defendants knowingly and intentionally provided financing and other forms of material support to al-Qaeda to further its international terrorism. See supra Points I.B.2 & I.B.3.
 
The ATS is a jurisdictional statute that Congress enacted as part of the Judiciary Act of 1789 on the “understanding that the common law would provide a cause of action for the modest number of international law violations with a potential for personal liability at that time,” namely “violation of safe conducts, infringement of the rights of ambassadors, and piracy.” Sosa v. Alvarez-Machain, 542 U.S. 692, 712, 724 (2004). In Sosa, the Supreme Court held that federal courts also may permit aliens to assert tort claims “based on the present-day law of nations” as long as they “rest on a norm of international character accepted by the civilized world and defined with a specificity comparable to the features of the 18th-century paradigms.” Id. at 724-25. In making this determination, courts should consider “the potential implications for the foreign relations of the United *122 States” and should be “wary of impinging on the discretion of the Legislative and Executive Branches in managing foreign affairs.” Id. at 727.
 
In cases decided after Sosa, this Court has looked to three factors to determine whether a claim adequately alleges a violation of customary international law that is cognizable in a tort action under the ATS. To state an ATS claim, the alleged tort must involve a violation of a norm of customary international law that is “(1) universal and obligatory, (2) specific and definable, and (3) of mutual concern [to States.]” Abdullahi v. Pfizer, Inc., 562 F.3d 163, 177 (2d Cir. 2009), cert. denied, 130 S. Ct. 3541 (2010). As the district court recognized, SPA233 (Terrorist Attacks V), aircraft hijacking has long been recognized as a violation of international law that meets these criteria and can give rise to tort claims under the ATS. See, e.g., Kadic v. Karadzic, 70 R3d 232, 239 (2d Cir. 1996); cf. United States v. Yunis, 924 F.2d 1086, 1092 (D.C. Cir. 1991). What the district court failed to recognize, however, is that the broader concept of international terrorism is also a violation of customary international law that is actionable under the ATS, and plaintiffs adequately alleged that defendants engaged in, and aided and abetted, illegal acts of international terrorism.
 
                    *123 A. Plaintiffs Alleged That Defendants Violated the ATS By Intentionally Facilitating International Terrorism
The Burnett plaintiffs allege that “the Defendants, individually, jointly and severally, aided and abetted, sponsored, financed, promoted, fostered, materially supported, or otherwise conspired to proximately cause the death and injury of innocent persons namely the Plaintiffs herein through and by reason of acts of international terrorism -- the heinous attacks of September 11, 2001.” JA970. “As a result and proximate cause of the Defendants’ sponsorship of terrorism in violation of the law of nations and customary principles of international law, the Plaintiffs suffered injury and damages as set forth herein.” JA972. Such allegations state a claim under the ATS because facilitation of international terrorism is a violation of customary international law that is universal, obligatory, specific and of mutual concern to States.
 
                    B. Acts of International Terrorism are a Violation of Customary International Law
In considering whether alleged violations of customary international law are universal, obligatory, specific and of mutual concern to States, courts consider whether the conduct is banned by international conventions and treaties ratified by an overwhelming majority of States, *124 condemned by binding United Nations Security Council resolutions, and repudiated by individual nations. See, e.g., Flores v. S. Peru Copper Corp., 414 F.3d 233, 256-57, 261-62 (2d Cir. 2003); Filartiga v. Pena-Irala, 630 F.2d 876, 881-84 (2d Cir. 1980). Because the Constitution specifically gives Congress the power to “define and punish ... Offenses against the Law of Nations,” U.S. Const., art. I, § 8, cl. 10, courts should also accord deference to Congress’s determination of what conduct constitutes an offense under the law of nations. See, e.g., Ex parte Quirin, 317 U.S. 1, 26 (1942).
 
Plaintiffs have stated valid ATS claims because international conventions, U.N. Security Council resolutions, the domestic laws of many nations, and laws enacted by Congress pursuant to its authority to define and punish offenses against the laws of nations all demonstrate that there is a universal and obligatory norm against the commission of and material support of international terrorism alleged here -- namely, transnational acts intended to cause death or serious bodily injury to civilians for the purpose of intimidating the population or compelling a government to do some act or refrain from acting.
 
                    *125 1. United Nations Security Council resolutions
The U.N. Security Council has adopted numerous resolutions condemning international terrorism and support for international terrorism. In 1998, for example, the Security Counsel adopted a resolution “[s]trongly condemn[ing] the terrorist bomb attacks” on the U.S. Embassies in Kenya and Tanzania on August 7, 1998 “which claimed hundreds of innocent lives, injured thousands of people, and caused massive destruction to property.” S.C. Res. 1189, U.N. Doc. S/RES/1189 (Aug. 13, 1998) at ¶ 1. Later in 1998, the Security Council issued a resolution expressing concern about the “continuing use of Afghan territory, especially areas controlled by the Taliban, for the sheltering and training of terrorists and the planning of terrorist acts, and reiterating that the suppression of international terrorism is essential for the maintenance of international peace and security.” S.C. Res. 1214, U.N. Doc. S/RES/1214 (Dec. 8, 1998) at preamble and ¶ 13 (emphasis in original). In addition to the Security Council, the U.N. General Assembly has also adopted resolutions condemning intentional terrorism, including the provision of support to terrorists. See, e.g., G.A. Res. 210, U.N. GAOR, 51st Sess., Annex 1 at 6, U.N. Dec. A/RES/51/210 (1997) (declar[ing] that knowingly *126 financing, planning and inciting terrorist attacks are ... contrary to the purposes and principles of the United Nations”).
 
Since the September 11th Attacks, the Security Council has continued to condemn international terrorism and the provision of material support for terrorism and to assert that it poses a serious threat to peace and security. See, e.g., S.C. Res. 1373 (Sept. 28, 2001) (deciding that States shall “[p]revent and suppress the financing of terrorist acts,” and “[c]riminalize the willful provision or collection, by any means, directly or indirectly, of funds by their nationals or in their territories with the intention that the funds should be used, or in the knowledge that they are to be used, in order to carry out terrorist acts”); S.C. Res. 1377 (Nov. 12, 2001) (declaring “that acts of international terrorism constitute one of the most serious threats to international peace and security in the twenty-first century, ... that acts of international terrorism constitute a challenge to all States and to all humanity”).
 
                    2. International conventions
The Security Council has defined international terrorism in accordance with the definition used in international treaties to combat international terrorism. See, e.g., S/RES 156 (Oct. 8, 2004) (recalling that *127 acts “which constitute offenses within the scope of and as defined in the international conventions and protocols relating to terrorism, are under no circumstances justifiable ... and calls upon all States to ... ensure that such acts are punished”). One of the principal treaties to combat international terrorism is the 1999 Financing Terrorism Convention. Article 2.1 of that Convention states:
     Any person commits an offence within the meaning of this Convention if that person by any means, directly or indirectly, unlawfully and willfully, provides or collects funds with the intention that they should be used, in full or in part, in order to carry out: (a) An act which constitutes an offence within the scope of and as defined in one of the treaties listed in the annex;115 or (b) Any other act intended to cause death or serious bodily injury to a civilian, or to any other person not taking an active part in the hostilities in a situation of armed conflict, when the purpose of such act, by its nature or context, is to intimidate a population, or to compel a government or an international organization to do or to abstain from doing any act.
 
 
International Convention for the Suppression of the Financing of Terrorism (Dec. 9, 1999) (1999 Financing Terrorism Convention), 2178 U.N.T.S. 197. The 1999 Financing Terrorism Convention was signed by at least 39 nations *128 before September 11, 2011, entered into force on April 10, 2002, and now has 132 signatories and 174 parties. See United States v. Bahlul, No. 09-001, 2011 U.S. CMCR LEXIS 3, at *126-27 (CMCR Sept. 9, 2011).
 
Most of the regional and multilateral conventions regarding terrorism employ a similar definition. See Interlocutory Decision on the Applicable Law: Terrorism, Conspiracy, Homicide, Perpetration, Cumulative Charges (Applicable Law for Special Tribunal for Lebanon), 50 I.L.M. 513, 536 (Spec. Trib. For Leb. July 2011) (discussing conventions). In addition, “all of these conventions require--through the definition of the actus reus (the material element of a crime) or by additional provisions--a transnational element to the crime.” Id. These international treaties and conventions support the conclusion that “conduct in support of terrorism [is] internationally condemned and criminal.” United States v. Hamdan, 801 F. Supp. 2d 1247, 1284 (CMCR 2011).
 
                    3. Domestic laws of nations
Countries throughout the world have adopted a similar definition of terrorism in their domestic law (although in some cases the domestic definition is broader than the definition in the international conventions because it does not include the transnational element). See, e.g., Applicable *129 Law for Special Tribunal for Lebanon, 50 I.L.M. at *537-39; Bahlul, 2011 U.S. CMCR Lexis 3, at *138-148. For these reasons, at least one international court has found that there is a general opinion and practice such that international terrorism is a violation of customary international law. See Applicable Law for Special Tribunal for Lebanon, 50 I.L.M. at *535; Hamdan, 801 F. Supp. 2d at 1288-92.
 
                    4. Congress and federal courts
United States courts have also found that there is a customary international law norm against international terrorism and the provision of material support for international terrorism. See Almog, 471 F. Supp. 2d at 284-85, 291-294 (finding plaintiffs stated ATS claims based on allegations that defendants committed acts of international terrorism that “essentially track the conduct specifically condemned in the Financing and Bombing Conventions, as well as in the ATA sections which implement those Conventions”); Bahlul, 2011 U.S. CMCR LEXIS 3, at *134-35 (rejecting argument that crime of providing material support for terrorism is a “novel domestic crime” that was not recognized or charged as a war crime before passage of the Military Commissions Act of 2006, because there is “ ‘ample evidence’ that an ‘intent’ or ‘manner calculated to influence or affect the *130 conduct of the government ... by intimidation or coercion,’ ... now constitutes ‘international custom’ ”); Hamdan, 801 F. Supp.2d at 1312 (“offense of providing material support to terrorism” is a violation of the law of war).
 
This conclusion is reinforced and “informed by the legislative guidance provided by Congress.” Almog, 471 F. Supp. 2d at 285. Congress, acting pursuant to its Constitutional authority to define and punish violations of the law of nations, has enacted the ATA provisions creating a civil cause of action for U.S. nationals injured by acts of international terrorism. See id. at 294; see also supra at pp. 66-72. Congress also enacted a provision of the Military Commissions Act of 2006 making it an offense to provide material support for terrorism, which is defined to include “provid[ing] material support ... for, or in carrying out an act of terrorism” and “intentionally provid[ing] material support or resources to an international organization engaged in hostilities against the United States.” 10 U.S.C. § 950v(b)(25)(A). Terrorism, in turn, is defined as the intentional killing or infliction of “great bodily harm” on protected civilians “in a manner calculated to influence or affect the conduct of the government or civilian population by intimidation or coercion, or to *131 retaliate against government conduct ....” Id. § 950v(b)(24). After an exhaustive review of the international treaties, Security Council Resolutions, and domestic laws of many nations, the U.S. Court of Military Commission Review recently held that these prohibitions on terrorism are “consistent with international norms applicable at the time” of the September 11th Attacks and “consistent with the general principles of law recognized by civilized nations.” Bahlul, 2011 U.S. CMCR LEXIS 3, at *149.
 
Recognizing international terrorism also fully accords with Sosa’s direction to consider “the potential implications for the foreign relations of the United States” and to be “wary of impinging on the discretion of the Legislative and Executive Branches in managing foreign affairs.” Sosa, 542 U.S. at 727. Like pirates, international terrorists such as al-Qaeda are widely reviled and prosecuted by all States. Indeed, many of the most effective counter-terrorism efforts directed against organizations such as al-Qaeda, in the fields of cross-border finance and otherwise, arise through the coordinated actions of many different types of States. This unanimity of action ensures that permitting ATS claims for international terrorism reflected in the September 11th Attacks has no potentially negative implications for the foreign relations of the United States, which of course *132 has focused its own foreign affairs over the past decade on eradicating and securing international support to eradicate just this type of international terrorism. Similarly, there is no risk of impinging on the coordinate Branches. Congress has through legislation opened the doors to civil claims and to criminal prosecutions for actions that facilitate international terrorism. See 18 U.S.C. §§ 2333, 2339A-2339C; see supra at pp. 99-100 (military prosecutions); Companion Brief, at Point I.A.3. And, the Executive Branch has vigorously implemented those statutes and pursued a range of enforcement actions against the financiers, supporters, and other agents of international terrorism in a manner entirely consistent with recognition of an ATS claim for international terrorism in this context. See Companion Brief at Point I.A.3.
 
                    C. International Terrorism Is Sufficiently Definite and of Mutual Concern to States
As the materials set out above indicate, transborder terrorism attacks undertaken by organizations such as al-Qaeda and its associates are just the sort of definite acts of mutual concern to States that the ATS is designed to enable. Whatever the definitional difficulties at the margins, concerning fighters in internal disturbances or civil wars or political parties with fringe militarist arms, those concerns do not apply to the September 11th Attacks. *133 Nothing in this Court’s decision in United States v. Yousef, 327 F.3d 56 (2d Cir. 2003) (per curiam), requires a different result. To be sure, the court in Yousef stated that “customary international law currently does not provide for the prosecution of ‘terrorist’ acts under the universality principle, in part due to the failure of States to achieve anything like consensus on the definition of terrorism.” Id. at 97. But it did so largely because there has been some disagreement among States on how to distinguish “terrorists” from “freedom fighters,” and because the district court had rested its holding on the Restatement (Third) of the Foreign Relations Law of the United States instead of primary sources of international law. Id. at 98-103, 107-08. Those concerns are not present here.
 
Any disagreement about how to characterize attacks by domestic attacks within a country by national liberation movements is inapplicable to al-Qaeda’s international terrorist attacks on innocent civilians in the United States. See Almog, 471 F. Supp. 2d at 281; Bahlul, 2011 U.S. CMCR LEXIS 3 at *128. And the primary sources of international law discussed above reveal a customary norm of international law that directly covers the acts of international terrorism alleged in these cases -- transnational attacks, *134 and the provision of material support for such attacks, on innocent civilians intended to influence the conduct of a government or population by intimidation or coercion. That norm is no “less definite [in] content ... than the historical paradigms familiar when [the ATS] was enacted.” Sosa, 532 U.S. at 732; cf. Abdullahi, 562 F.3d at 184 (although there are varying definitions of piracy, it is actionable under the ATS because “ ‘whatever may be the diversity by definitions,’ ” there was a consensus “ ‘that robbery or forcible depredations upon the sea ... is piracy’ ”) (quoting United States v. Smith, 18 U.S. (5 Wheat) 153, 159-61 (1820)).
 
Finally, international terrorism is clearly “capable of impairing international peace and security,” Mores, 414 F.3d at 249, a factor this court has found to be “important” in demonstrating that the international law norm is of “ ‘mutual’ concern to States,” and thus actionable under the ATS, Abdullahi, 562 F.3d at 185. The U.N. Security Council Resolutions specifically state as much, see supra at Point n.b.2, and the United States invaded Afghanistan because the Taliban regime had supported al-Qaeda prior to the September 11th Attacks. See Hamdan v. Rumsfeld, 548 U.S. 557 567-68 (2006) (discussing Authorization for Use of Military Force, 115 Stat. 224 (2001)).
 
*135 For these reasons, there is a customary international norm against the commission of and provision of material support for acts of international terrorism that is sufficiently universal, obligatory, definite, and of mutual concern to States to give rise to a claim under the ATS. Thus, plaintiffs’ allegations that defendants purposefully provided financing and other forms of material support to al-Qaeda to further its terrorist mission to attack the United States and its nationals state a claim under the ATS, without regard to whether they also state a claim for aiding and abetting the September 11th Attacks. The district court therefore erred as a matter of law in dismissing the ATS claims on the ground that they failed to allege that defendants “purposefully aided and abetted, conspired with, or materially supported al Qaida in the commission of an act of terrorism involving the hijacking of a commercial airplane.” SPA233 (Terrorist Attacks V) (emphasis added).
 
                    III. The District Court Improperly Dismissed the Torture Victim Protection Act Claims
Plaintiffs also brought claims under the Torture Victim Protection Act (“TVPA”), which provides a cause of action for victims of torture or extrajudicial killings perpetrated by “individual[s]” acting “under actual or apparent authority, or color of law, of any foreign nation.” 28 U.S.C. § 1350 *136 note. The district court dismissed plaintiffs’ TVPA claims against defendants Al Rajhi Bank, Saudi American Bank, and National Commercial Bank on the ground that corporate entities are not “individuals” who may be sued under the TVPA. SPA52 (Terrorist Attacks I) (citing Arndt v. UBS AG, 342 F. Supp. 2d 132, 141 (E.D.N.Y. 2004)). This conclusion is incorrect, and the issue is likely soon to be definitively resolved by the U.S. Supreme Court, which is considering a pending case presenting this issue.
 
As an initial matter, this Court has already indicated that an organizational defendant can be sued under the TVPA in Khulumani v. Barclay Nat’l Bank. Ltd., 504 F.3d 254 (2d Cir. 2007). In Khulumani, the plaintiffs asserted aiding and abetting claims under the TVPA against a bank for its participation in the torture and extrajudicial killings committed by the South African apartheid regime. Id. at 259. This Court dismissed the TVPA claims on the ground that the plaintiffs failed to allege that the bank had acted under color of law, but it did not question whether the bank was a proper defendant under the TVPA in the first place. Id. at 260. Based on Khulumani, the district court later held that a “corporation or other entity may ... be subject to liability under the TVPA for aiding and *137 abetting” a principal violator. SPA210 (Terrorist Attacks IV); accord SPA234 (Terrorist Attacks V).
 
More importantly, the Supreme Court recently granted certiorari in Mohamad v. Rajoub, 132 S. Ct. 454 (2011), which will resolve a circuit split over whether the TVPA permits actions against non-natural persons. Compare Sinaltrainal v. Coca-Cola Co., 578 F.3d 1252, 1258 n.5 (11th Cir. 2009) (allowing TVPA action against corporate defendant), and Khulumani, 504 F.3d at 260, with Mohamad v. Rajoub, 634 F.3d 604, 607-08 (D.C. Cir. 2011) (holding that TVPA liability does not extend to non-natural persons), and Aziz v. Alcolac, Inc., 658 F.3d 388, 392 (4th Cir. 2011) (same), and Bowoto v. Chevron Corp., 621 F.3d 1116, 1126-27 (9th Cir. 2010) (same). In the interest of judicial economy, plaintiffs respectfully request that this Court defer deciding their appeal of the dismissal of their TVPA claims until the Supreme Court has decided Mohamad and the Court can obtain the benefit thereafter of the parties’ views of the implications of that decision for this case.
 
Alternatively, should Mohamad not result in an opinion or if this Court is inclined to reach a decision on the TVPA claims independently of Mohamad, it should vacate the district court’s dismissals. The TVPA *138 creates an action in tort and, therefore, should be interpreted in light of the well-established common law (and international law) presumption that organizations are liable in tort for the acts of their agents. See Balt. & Potomac R.R. v. Fifth Baptist Church, 108 U.S. 317, 330 (1883); Br. for Petitioners at 12-17, Mohamad v. Palestinian Authority, No. 11-88 (Sup. Ct. Dec. 14, 2011) (“Mohamad Br.”). Moreover, the TVPA’s use of the term “individual” comports with this presumption because this term has often been construed as synonymous with the term “person,” which has a broad legal meaning that includes organizational entities, such as corporations. See, e.g., Clinton v. City of New York, 524 U.S. 417, 428 & n.13 (1998); Mohamad Br. at 19-20 (citing cases from federals courts of appeals); see also id. at 17-18 (noting that dictionary definitions of the word “individual” often include non-natural entities).
 
Furthermore, such a broad interpretation is consistent with the structure of the TVPA, which incorporates agency principles by imposing liability on individuals who “subject[]” a victim to torture or extrajudicial killing. Id. at 25-26. This construction also is consistent with the fact that organizational liability exists under other federal statutes that provide civil remedies to victims of torture and extrajudicial killing. See, e.g., *139 Brentwood Acad. v. Term. Secondary Sch. Athletic Ass’n, 531 U.S. 288 (2001) (permitting a section 1983 suit against an association); Ungar v. Palestine Liberation Org., 402 F.3d 274, 276 (1st Cir. 2005) (affirming ATA judgment against terrorist organizations); Murphy v. Islamic Republic of Iran, 740 F. Supp. 2d 51, 72 (D.D.C. 2010) (finding terrorist organization liable under 28 U.S.C. § 1605A(c)); see also Mohamad Br. at 30-34. Finally, the legislative history of the TVPA reveals that Congress’s use of the term “individual” in the TVPA was only to “make crystal clear that foreign states or their entities cannot be sued ....” S. Rep. No. 102-249, at 6 (1991), and that Congress repeatedly assumed that organizations would be proper defendants in TVPA lawsuits. Mohamad Br. at 43-49. For these and other reasons elaborated in the briefs before the Supreme Court in Mohamad, Congress clearly intended the TVPA to provide a remedy against a broader set of defendants that includes entities other than natural persons.
 
                    IV. The District Court Improperly Dismissed the Negligence And Intentional Tort Claims
Plaintiffs pleaded a number of state law tort claims against defendants subject to this appeal, including negligence, negligent infliction of emotional distress (“NIED”), intentional infliction of emotional distress (“LIED”), assault and battery, trespass, and recovery under New York’s *140 wrongful death and survival statutes. The district court wrongly dismissed claims against defendants under each of these theories of tort liability.
 
                    A. The District Court Wrongly Dismissed the Negligence Claims