Case 1:20-mc-00036-JEB-DAR Document 10 Filed 08/18/20 Page 12 of 29 and any individual, partnership, association, joint stock company, trust, or corporation.”12 Notably, only United States governmental agents or employees, U.S. state governmental agents or employees, and local U.S. governmental agents and employees are included within the definition of the term “person”— foreign governmental employees and agents are not within that definition. Moreover, foreign governmental agents or employees cannot be included under the term “individual.” If all governmental agents and employees qualified as “individuals” then the language “any employee, or agent of the United States or any State or political subdivision thereof” would be entirely superfluous. That cannot be the case given that Courts take great care to construe statutes as to give meaning to every term. Delaware Dep't of Nat. Res. & Envtl. Control v. Envtl. Prot. Agency, 895 F.3d 90, 99 (D.C. Cir. 2018) (“Additionally, we strive to construe statutes ‘so that effect is given to all its provisions, so that no part will be inoperative or superfluous, void or insignificant.’”). Moreover, the Myanmar government cannot fall within the definition of “entity.” Nothing in the statute says an “entity” is a government body or actor. Indeed, the statute does not define “entity.” Where words are undefined, courts will strive to give them their ordinary meaning. Sandifer v. U.S. Steel Corp., 571 U.S. 220, 227 (2014) (“It is a ‘fundamental canon of statutory construction’ that, ‘unless otherwise defined, words will be interpreted as taking their ordinary, contemporary, common meaning.’”). Black’s Law dictionary defines “entity” as “[a]n organization (such as a business or a governmental unit) that has a legal identity apart from its members or owners.”13 Because, courts construe statutory texts “harmoniously” and in relation to neighboring words, here, “entity” should be construed in relation to “person.” See Yates v. 12 13 18 U.S.C. § 2510 (6) (2020) (emphasis added). Black’s Law Dictionary (11th ed. 2019). 6

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