The case of the day is EIG Energy Fund XIV, LP v. Petroleo Brasileiro, S.A. (D.C. Cir. 2018). The case arose out of the Petrobras scandal in Brazil, in which Petrobras, the state oil company, allegedly defrauded EIG and other investors who sank millions into a major oil extraction project off the Brazilian coast, only to suffer losses when corruption in the Brazilian government and in Petrobras killed the project. The details of the alleged corruption aren’t important for our story. What’s important is that several EIG entities brought actions against Petrobras, and Petrobras asserted that it was immune from jurisdiction under the FSIA. The question was whether Petrobras’s commercial activity had caused a direct effect in the United States.