Mori v. International Brotherhood of Boilermakers, Iron Ship Builders, Blacksmiths, Forgers & Helpers, Local Lodge No. 6

applying pre-UCC contract law principles to a letter of credit governed solely by the UCPDC | Nigerian government's purchase of cement was a commercial activity irrespective of its purposes for so doing | “Breach of an agreement is necessarily performed ‘in connection with’ that agreement, or with a series of similar agreements.” | claims arising out of foreign country’s breach of contracts to purchase cement fall within commercial activity exception to immunity | “[s]ince service [of process] was made under Section 1608, the relevant area in delineating contacts is the entire United States, not merely New York [the forum state]” | in the case of a foreign corporation, the relevant inquiry is whether the corporation has suffered direct financial loss | government of Nigeria liable for breach of contract for the purchase of nearly $1 billion worth of cement, even though it was to be used to build army barracks | "Act of state analysis depends upon a careful case-by-case analysis of the extent to which the separation of powers concerns on which the doctrine is based are implicated by the action before the court." | “Act of state analysis depends upon a careful case-by-case analysis of the extent to which the separation of powers concerns on which the doctrine is based are implicated by the action before the court.” | an agency’s sanction upheld when it properly applied its own guidelines and regulations | where service of process is made upon the instrumentality of a foreign state pursuant to § 1608 of the Foreign Sovereign Immunities Act, the relevant geographic area for determining defendant’s contacts is the United States, not merely New York | When a federal court’s subject matter jurisdiction exists by virtue of a federal question and the method of service is authorized by federal provision, “the relevant area in delineating contacts is the entire United States, not merely [the forum state].”