Memorandum de las armadoras

Case 1:21-cv-11269-FDS Document 67 Filed 11/22/21 Page 58 of 58

CERTIFICATE OF SERVICE I hereby certify that, on November 22, 2021, the foregoing document was served upon all counsel of record through this Court’s electronic filing system as identified in the Notice of Electronic Filing, and paper copies will be sent to those indicated as nonregistered participants. /s/ Andrew E. Lelling Andrew E. Lelling (BBO No. 631859) alelling@jonesday.com 100 High Street JONES DAY Boston, MA 02110-1781 Phone: (617) 449-6856 Fax: (617) 449-6999

49

Turn static files into dynamic content formats.

Create a flipbook

Articles inside

D. Apportioning damages and liability would be unworkable

Case 1:21-cv-11269-FDS Document 67 Filed 11/22/21 Page 2 of

C. The Mexican government’s alleged harms are derivative of other victims

b) Mexico has not plausibly alleged a violation of any firearms- specific statute

2. This case involves a domestic application of the PLCAA

B. Intervening intentional criminal acts break the chain of causation

c) The predicate exception does not allow claims based on generally applicable consumer-protection statutes

B. This Suit Is a “Qualified Civil Liability Action” under the PLCAA

d) Mexico cannot satisfy PLCAA’s proximate-cause requirement

B. The complaint admits facts confirming that Mexico’s alleged harms are not fairly traceable to defendants’ actions

D. The PLCAA Applies to Claims by Foreign Governments

Issuu converts static files into: digital portfolios, online yearbooks, online catalogs, digital photo albums and more. Sign up and create your flipbook.