The Rep. of Ecuador v. Dassum and Dassum, 146 So. 3d 58

Ecuador seeks to recover approximately $200 million from two former Ecuadorian bankers, the Isaias brothers, in Florida.
Filanbanco, previously Ecuador's largest bank, faced a liquidity crisis and was put into liquidation with AGD involvement.
Deloitte issued a report (approved by Ecuadorian authorities) concluding the Isaiases owed about $661.5 million; EC authorities attributed losses to alleged misconduct.
The AGD in Ecuador recovered and sold assets in Ecuador totaling around $400 million to reduce the alleged liability.
In Florida, the Republic filed suit seeking damages; the complaint does not seek immediate seizure of property in Florida.
The trial court granted summary judgment for the Isaiases under the act of state doctrine and its extraterritoriality implications, which the Republic appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether extraterritoriality exception bars Florida claims	Isaias	Isaias	Remanded; genuine factual issues exist
Whether the Florida complaint seeks enforcement of a confiscation in the US	Republic	Isaias	Not precluded; seeks damages, may proceed
Whether Florida court should give preclusive effect to Deloitte/AGD findings	Republic	Isaias	Not required; not out-of-country judgments

Banco Nacional de Cuba v. Sabbatino, 376 U.S. 398 (1964) (establishes act of state deference principle)
National Indus. v. Kane, 153 So. 2d 40 (Fla. 3d DCA 1963) (defers to foreign acts within territory)
Republic of Philippines v. Marcos, 806 F.2d 344 (2d Cir. 1986) (foreign government recovery of assets from former regime)
Bandes v. Harlow & Jones, Inc., 852 F.2d 661 (2d Cir. 1988) (extraterritoriality exception allows US action on assets in US)
Republic of Iraq v. First Nat’l City Bank, 353 F.2d 47 (2d Cir. 1965) (extraterritoriality exception framework for governmental seizures)
Nahar v. Nahar, 656 So. 2d 225 (Fla. 3d DCA 1995) (comity considerations in international matters)