54 356 FEDERAL SUPPLEMENT, 3d SERIES Court to send the aforementioned package to ‘‘the Secretary of State in Washington, District of Columbia, to the attention of the Director of Special Consular Services—and the Secretary shall transmit one copy of the papers through diplomatic channels to the foreign state and shall send to the clerk of the court a certified copy of the diplomatic note indicating when the papers were transmitted.’’ 28 U.S.C. § 1608(a). North Korea has neither made a special arrangement for service with the plaintiffs, Hatch Decl. ¶ 19, nor entered into any international convention governing service, see ATTORNEY MANUAL FOR SERVICE OF PROCESS ON A FOREIGN DEFENDANT, UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA 6 (July 2018) (‘‘North Korea is not a party to the [Hague] ConventionTTTT’’). Instead, North Korea was served here under the third option: the necessary papers were mailed through DHL and delivered to North Korea on June 19, 2018, see Return of Service, ECF No. 12. Accordingly, the plaintiffs have established that service was properly effected against the defendants and, thus, personal jurisdiction is properly exercised. C. North Korea’s Liability Section 1605A not only ‘‘provides federal courts with jurisdiction over, and withdraws sovereign immunity from’’ certain suits, see 28 U.S.C. § 1605A(a)(1), but 5. The plaintiffs bring three other claims based on common law torts. See Compl. ¶¶ 67–70 (Second Claim for Relief based on wrongful death and survival); id. ¶¶ 71–74 (Third Claim for Relief based on intentional infliction of emotional distress); id. ¶¶ 75–77 (Fourth Claim for Relief based on assault and battery). The D.C. Circuit has explained that while a plaintiff may rely on ‘‘alternative sources of substantive law,’’ including ‘‘state tort law,’’ to bring a claim against a foreign state after establishing a waiver of sovereign immunity through the FSIA’s terrorism exception, such ‘‘also creates a federal cause of action directly against foreign governments,’’ Fraenkel v. Islamic Republic of Iran, Ministry of Foreign Affairs, 892 F.3d 348, 352–53 (D.C. Cir. 2018). ‘‘Under § 1605A(c), ‘national[s] of the United States’ may sue certain foreign governments—those designated by the U.S. government as state sponsors of terrorism— for the acts described in § 1605A(a)(1),’’ id. at 353 (alteration in original) (quoting § 1605A(c) ), such as torture, hostage taking and extrajudicial killing, ‘‘causing ‘personal injury or death,’ ’’ id. at 352–53 (quoting § 1605A(c) ). The statute specifies that, ‘‘[i]n any such action, damages may include economic damages, solatium, pain and suffering, and punitive damages.’’ Id. (alteration in original) (internal quotation marks omitted) (quoting § 1605A(c) ). Here, the plaintiffs, who are all citizens of the United States, have established their first claim for relief, which seeks to hold North Korea liable under § 1605A(c), the FSIA terrorism exception’s private right of action. See Compl. ¶¶ 57–66 (First Claim for Relief Action for Damages Under 28 U.S.C. § 1605A(c) ); Pls.’ Mot. at 35–36, 38.5 To determine liability under Section 1605A(c), ‘‘the elements of immunity and liability TTT are essentially the same,’’ Kilburn v. Islamic Republic of Iran, 699 F.Supp.2d 136, 155 (D.D.C. 2010), and liability under section 1605A(c) will, in most cases, ‘‘exist whenever the reliance is not needed. See Owens, 864 F.3d at 808–09 (‘‘[I]n most cases brought under the new terrorism exception, the plaintiff need not rely upon state tort law.’’). Accordingly, discussion of the plaintiffs’ tort-based claims for relief is unnecessary, since those claims would give rise to no more damages than those available under the FSIA’s private right of action, see 28 U.S.C. § 1605A(c), and are therefore ‘‘subsumed in the FSIA claims.’’ Kaplan v. Cent. Bank of the Islamic Republic of Iran, 896 F.3d 501, 508 (D.C. Cir. 2018).