country. Carol Sachs, a US resident, purchased a Eurail pass on the internet from a US-based travel agent. She used the pass to board a train operated by the Austrian national railway, ÖBB Personenverkehr AG (ÖBB), but during the process she fell onto the tracks and her legs were crushed by the moving train, requiring the amputation of both of her legs. Sachs sued ÖBB in the United States District Court for the Northern District of California for damages related to the incident. She reasoned that the suit was not barred by the FSIA because it was "based upon" the sale of the ticket by the US-based travel agent. The court ruled that the suit did not fall within the commercial activities exception. It was appealed to the United States Court of Appeals for the Ninth Circuit, which reversed the judgment, holding that the purchase of the ticket from a US-based travel agent established agency. The Supreme Court looked at the "particular conduct on which the [lawsuit] is based" and held that, because that conduct occurred in Austria, the case did not fall within the commercial activities exception. Genocidal takings One student's note has argued that matters of genocidal takings are regarded as exceeding the jurisdictional limits of the FSIA's international takings exception. In June 2017, a divided panel of the United States Court of Appeals for the District of Columbia Circuit found the FSIA did not prevent the survivors of a Holocaust victim from suing to recover art stolen by Nazi plunderers. However, the ruling was challenged by Germany to the United States Supreme Court, which ruled in a unanimous decision in February 2021 that FSIA does not permit legal action to be taken against foreign states for property taken from individuals by foreign states, as the provisions of FSIA are directed towards state property taken by other states, and vacated the lower court rulings. The case, Germany v. Philipp, dealt with the applicability of the FSIA for heirs of victims of the Holocaust to sue Germany in the United States court systems for compensation for items that were taken by the Nazi Party during World War II. The court unanimously ruled that FSIA does not allow these survivors to sue Germany in U.S. court, reasoning that the sale was an act of expropriation of property rather than an act of genocide, although granting that other means of recovery