are still potentially available. The decision also concluded a related case, Hungary v. Simon, which was decided per curiam on the ruling of Germany. Industrial espionage by state-owned enterprises FSIA has been invoked by state-owned enterprises as well as their subsidiaries and joint ventures, particularly those owned by the People's Republic of China, accused of industrial espionage and intellectual property theft, as a defense from legal action. Notable legal cases Cicippio-Puleo v. Islamic Republic of Iran in 2004 was heard after the additions of the Antiterrorism and Effective Death Penalty Act of 1996 and the Flatow Amendment to FSIA, which were related to punitive damages from emotional distress from family members of a surviving Lebanon hostage crisis from Iran. While an earlier case by the hostage was successful in winning compensatory damages in his original suit, the DC Circuit Court ruled that the amended FSIA did not allow for a private cause of action against a foreign nation, only against individuals. This decision filtered through the other circuit courts, which prompted Congress to significantly modify the exemptions related to terrorism in the 2008 NDAA to specifically allow for foreign nations to be sued on a private cause of action, retroactively applying this to the other legal cases pending at the time. In 2008, Saudi Arabia invoked the FSIA to preclude a lawsuit filed by families and victims of the September 11 attacks who alleged that the Saudi leaders had indirectly financed al-Qaeda. Congress responded in 2016 by overriding President Obama's veto of the Justice Against Sponsors of Terrorism Act (JASTA), amending FSIA and allowing the families' suit against Saudi Arabia to proceed in U.S. courts. In John V. Doe v. Holy See, 557 F.3d 1066 (9th Cir. 2009), the Holy See invoked the FSIA in a lawsuit related to child abuse incidents in various U.S. churches. The ruling ultimately did not rely on state immunity. In Republic of Argentina v. NML Capital, Ltd., the Supreme Court ruled on June 16, 2014, against Argentina's appeal of a lower court ruling that Argentina's government must uphold its contractual obligation to pay in full those bondholders who refused to accept reduced payments negotiated in foreign debt restructurings carried out by Argentina in 2005 and 2010 after that nation's government defaulted on its debt in 2001. Later the same day, the U.S. Supreme Court, in a 7–1 ruling (Associate Justice Sonia Sotomayor recused herself