Without question, the historical events described in the Amended Complaint caused great suffering and deep scars in this nation's history. But it is also beyond debate that our judicial system is not a proper forum for redressing the grievances arising from that era. Without alleging any connection between themselves or their ancestors and these present-day companies named as defendants, plaintiffs seek to use the courts to examine a tragic period in our nation's history. But plaintiffs cannot meet the basic requirements of standing, timeliness, and justiciability; nor can they state a cognizable claim. Defendants respectfully request that plaintiffs' Amended Complaint be dismissed with prejudice.