144. ALTMANN incorporates here by reference paragraphs 1 through 97.

145. The AUSTRIAN GALLERY violated international law by knowingly participating in and profiting from the Nazi persecution of Ferdinand Bloch in the following ways: (1) the AUSTRIAN GALLERY assisted in the systematic looting of the property of Ferdinand Bloch-Bauer; (2) the AUSTRIAN GALLERY obtained artworks belonging to Ferdinand Bloch-Bauer during the War; (3) the AUSTRIAN GALLERY refused to return artworks to Ferdinand Bloch-Bauer and his heirs after the War; (4) the AUSTRIAN GALLERY used duress and deceit to obtain artworks that should have been restituted to Ferdinand’s heirs during the post-war period, and (5) the AUSTRIAN GALLERY concealed its misdeeds from the heirs until they were exposed in 1998-99.

146. As determined by the United States Congress in Title II of the Holocaust Victims Redress Act of 1998, the above referenced actions by the AUSTRIAN GALLERY were in violation of numerous international treaties, customary international laws, and fundamental human rights laws prohibiting war crimes, including, or as reflected by the United Nations Charter, the Universal Declaration of Human Rights, the Geneva Convention of 1929, the supplemental Geneva Convention of the Treatment of Non-Combatants During World War Time, the Nuremberg Principles, the Covenant on Civil and Political Rights, and the Hague Convention of 1907.

147. As a result of the above referenced violations of international law, ALTMANN has suffered injury and is entitled to judgment, against the AUSTRIAN GALLERY on this cause of action for compensatory damages in an amount to be determined by the Court.