Wang v. Islamic Republic of Iran
CourtDistrict Court, District of Columbia
Date FiledNovember 10, 2026
DocketCivil Action No. 2022-0583
JudgeJudge Timothy J. Kelly
StatusPublished
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Full Opinion
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF COLUMBIA
XIYUE WANG, et al.,
Plaintiffs,
v. Civil Action No. 22-583 (TJK)
ISLAMIC REPUBLIC OF IRAN
Defendant.
ORDER
In March 2025, the Court entered default judgment against the Islamic Republic of Iran
and ordered it to pay $59,770,566.00. ECF Nos. 24, 25. Plaintiffs now move for an order under
28 U.S.C. § 1610(c) authorizing enforcement of the judgment. ECF No. 31. For the reasons be-
low, the Court will grant their motion.
The Foreign Sovereign Immunity Act—or the FSIA—details a process for the enforcement
of a judgment against foreign states. See 28 U.S.C. § 1610. To obtain a § 1610(c) order allowing
execution and attachment to commence, plaintiffs must satisfy two requirements. “First, they need
to show that they have provided notice of their judgment to the defendant, consistent with the
requirements of the Foreign Sovereign Immunities Act, section 1608(e).” Ewan v. Islamic Repub-
lic of Iran, No. CV 17-1628 (JDB), 2026 WL 237562, at *1 (D.D.C. Jan. 29, 2026); see 28 U.S.C.
§ 1610(c). Notice of an entry of judgment must be accomplished “in accordance with the four
service methods provided in § 1608(a).” Sotloff v. Syrian Arab Republic, No. 16-cv-725 (TJK),
2024 WL 747262 *1 (D.D.C. Feb. 21, 2024). A plaintiff must exhaust each 1608(a) method “se-
quentially,” beginning with § 1608(a)(1). Id. Second, “plaintiffs must demonstrate that ‘a reason-
able period of time’ has elapsed following the entry of judgment, delivery of notice, and the
plaintiffs’ request for an order certifying attachment and execution to begin.” Ewan, 2026 WL
237562, at *2. “As for what a ‘reasonable’ time means, the statute says nothing more, but ‘the
sweep of the case law supports . . . that even a few months is sufficient.’” Sotloff, 2024 WL 747262
*1 (cleaned up).
Plaintiffs meet the mark here. Start with notice of the judgment. Sections 1608(a)(1) and
1608(a)(2) do not apply to lawsuits against Iran. See Ewan, 2026 WL 237562, at *2. So Plaintiffs
attempted service under § 1608(a)(3) but were unsuccessful. See ECF Nos. 26, 28. Thirty days
later, Plaintiffs attempted service under § 1608(a)(4). ECF Nos. 27, 28. Although Iran refused to
accept delivery, service was still proper. See ECF No. 30-1 at 8; Bernhardt v. Islamic Republic of
Iran, No. CV 18-2739 (TJK), 2023 WL 2598677, at *12 (D.D.C. Mar. 22, 2023). Plaintiffs thus
clear the first hurdle to obtaining a § 1610(c) order.
Up next is the “reasonable time” requirement. See 8 U.S.C. § 1610(c). Plaintiffs waited
more than two and a half months after notifying Iran before moving for a § 1610(c) order. Alt-
hough it is a somewhat close call, that amounts to a “reasonable time.” The “reasonable time
requirement exists because foreign sovereigns act through their bureaucracies and if the foreign
government intends to pay the judgment, it should be given time to do so.” Eurofinsa, S.A. v.
Gabonese Republic, No. CV 23-3013 (RC), 2025 WL 1650493, at *2 (D.D.C. June 11, 2025)
(internal quotation marks omitted). Now, around six months after Plaintiffs filed their motion and
nine months after Plaintiffs served Iran, there is still “no indication that [it is] taking any steps to
pay the judgment.” Kapar v. Islamic Republic of Iran, 105 F. Supp. 3d 99, 108 (D.D.C. 2015);
see ECF No. 31 at 3. With that context, the Court finds that Plaintiffs gave Iran a “reasonable
time” to respond. See Ned Chartering & Trading, Inc. v. Republic of Pakistan, 130 F. Supp. 2d
64, 67 (D.D.C. 2001) (finding that six weeks was reasonable time).
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For the above reasons, it is hereby ORDERED that Plaintiffs’ Motion for Order Author-
izing Enforcement of Judgment, ECF No. 31, is GRANTED. It is further ORDERED that Plain-
tiffs may seek attachment or execution of the judgment under any method authorized by 28 U.S.C.
§ 1610.
SO ORDERED.
/s/ Timothy J. Kelly
TIMOTHY J. KELLY
United States District Judge
Date: November 10, 2026
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