Petitioners seek to rebut an argument that Respondent has never made. Specifically, Petitioners suggest that one of Respondent's "principal arguments" was rejected by the D.C. Circuit in Process & Indus. Dev. Ltd. v. Federal Republic of Nigeria, No. 21-7003, 2022 U.S. App. LEXIS 6300 (D.C. Cir. Mar. 11, 2022) ("P&ID"). According to Petitioners, Respondent has supposedly argued-as Nigeria did in P&ID-that the arbitration exception under the Foreign Sovereign Immunities Act ("FSIA") at 28 U.S.C. § 1605(a)(6) "does not apply because [Petitioners] lack a valid and enforceable award."
Accordingly, because nothing in P&ID alters this Court's previous analysis, the Motion to Extend the Stay should be granted, as explained in Respondent's Motion, Reply, and Sur-Surreply (ECF Nos. 201, 208, 222).