Joint Statement gave the cocoa industry three more years to implement the protocol. The Joint Statement stated industry would form a certification system for half of the growing regions in Côte d'Ivoire and Ghana. The Joint Statement also stated industry would support programs for the local cocoa-growing communities including teacher training programs. The US Congress was not satisfied with the cocoa industry's response. It gave responsibility to the US Department of Labor to find a university contractor to oversee the efforts to eliminate the worst forms of child labor. In 2006, a $4.3 million contract was awarded to the Payson Center for International Development at Tulane University through 2009. In 2006, the Payson Center reported progress had been made, but children were still working in cocoa production, including performing dangerous tasks, and regularly miss school. The cocoa industry was criticized for a lack of certification standards and the governments of Côte d'Ivoire and Ghana were criticized for a lack of transparency. In 2006, the president of the World Cocoa Foundation said, "While progress has been made and we have learned valuable lessons, much more is required." After the deadline passed, the International Labor Rights Fund filed a lawsuit in 2005 under the Alien Tort Claims Act against Nestlé, Cargill and Archer Daniels Midland on behalf of three Malian children. The suit alleged the children were trafficked to Côte d'Ivoire, forced into slavery, and experienced frequent beatings on a cocoa plantation. In September 2010, the US District Court for the Central District of California determined corporations cannot be held liable for violations of international law and dismissed the suit. The case was appealed to the US Court of Appeals. 2008 progress and Joint Statement By the revised deadline—1 June 2008—all the objectives were still not met. Some progress had been made; for example, the cocoa industry had provided $10 million to the ICI. In 2006–07 the ICI had 17 training sessions in Côte d'Ivoire and 23 in Ghana to sensitize the governmental officials, police and media about child and adult labor practices. The focus of the Joint Statement was that of certification. The cocoa industry performed data collection had on 50% of the growing areas in both Côte d'Ivoire and Ghana. But independent verification, partially funded by industry, on those areas was not fully completed. The deadline was extended until the end of 2010. At that time, industry was required to