34 950 FEDERAL SUPPLEMENT, 2d SERIES ‘‘establishes his claim or right to relief by evidence that is satisfactory to the Court.’’ 28 U.S.C. § 1608(e). The ‘‘satisfactory to the court’’ standard is identical to the standard for entering default judgment against the United States under Fed.R.Civ.P. 55(d) (requiring claimant to ‘‘establish[ ] a claim or right to relief by evidence that satisfies the court’’). Hill v. Republic of Iraq, 328 F.3d 680, 683 (D.C.Cir.2003) (citing H.R.Rep. No. 94–1487, at 26 (1976)). Neither standard, however, is easily defined. See Smith ex rel. Smith v. Islamic Emirate of Afghanistan, 262 F.Supp.2d 217, 223 (S.D.N.Y.2003) (observing that ‘‘[t]he issue appears to have defied definitive resolution largely because in most cases the evidence of the defaulting defendant’s liability is quite compelling and thus the matter can be decided without a more concise meaning of ‘evidence satisfactory to the court’ ’’). The D.C. Circuit has not addressed the question, and lower courts have articulated varying rationales for what quantum of evidence is ‘‘satisfactory.’’ Some courts in FSIA default proceedings have found to be ‘‘satisfactory’’ evidence that they described as ‘‘clear and convincing.’’ See, e.g., Weinstein v. Islamic Republic of Iran, 184 F.Supp.2d 13, 16 (D.D.C.2002) (finding jurisdictional facts ‘‘established by clear and convincing evidence, which would have been sufficient to establish a prima facie case in a contested proceeding’’); Mousa v. Islamic Republic 1. This case was reversed in part by Hill v. Republic of Iraq, 328 F.3d 680 (D.C.Cir.2003). The D.C. Circuit rejected the burden of proof on damages for default judgment that the district court articulated, but ‘‘did not address the question of the FSIA’s plaintiff’s burden on proof on liability.’’ Hill, 328 F.3d at 683– 84. 2. The Federal Rule of Civil Procedure 50(a) standard is more stringent than the Ungar of Iran, 238 F.Supp.2d 1, 3 (D.D.C.2001) (same). But the reasoning of these cases suggests strongly—and in some cases indicates explicitly—that clear and convincing evidence was considered a sufficient, rather than a necessary, quantum of proof. See, e.g., Campuzano v. Islamic Republic of Iran, 281 F.Supp.2d 258, 269 (D.D.C. 2003) (concluding that ‘‘the plaintiffs have gone beyond the necessary burden of ‘evidence satisfactory to the court’ and have proven each element by clear and convincing evidence’’). Other courts have drawn an analogy between the FSIA default standard and that for judgment as a matter of law, either after a jury trial or on summary judgment. One court held that the FSIA default standard ‘‘call[s] for proof by evidence of a nature and quality sufficient to support summary judgment under Fed.R.Civ.P. 56, namely, oral or written testimony under oath, made upon personal knowledge by witnesses competent to testify to the matters stated therein.’’ Hill v. Republic of Iraq, 175 F.Supp.2d 36, 38 n. 4 (D.D.C. 2001) (referring to then-current Rule 56(e)).1 In Ungar v. Islamic Republic of Iran, 211 F.Supp.2d 91, 98 (D.D.C.2002), the court considered the Hill standard, among others, but then purported to opt for the standard for judgment as a matter of law after a jury trial, set forth in Federal Rule of Civil Procedure 50(a), which the court described as ‘‘a legally sufficient evidentiary basis for a reasonable jury to find for plaintiff.’’ Id. at 98.2 Several subsecourt’s formulation suggests. Judgment as a matter of law against a party may be granted only if ‘‘the court finds that a reasonable jury would not have a legally sufficient evidentiary basis to find for the party on [an] issue.’’ Fed.R.Civ.P. 50(a); see also Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 250, 106 S.Ct. 2505, 91 L.Ed.2d 202 (1986) (holding that the summary judgment standard ‘‘mirrors the standard for a directed verdict under Federal Rule of Civil Procedure 50(a), which is that