HAN KIM v. DEMOCRATIC PEOPLE’S REPUBLIC OF KOREA Cite as 950 F.Supp.2d 29 (D.D.C. 2013) for abuse to constitute torture it must be inflicted intentionally, not merely incidentally. Id. at 93 (‘‘In order to lose its sovereign immunity, a foreign state must impose suffering cruelly and deliberately, rather than as the unforeseen or unavoidable incident of some legitimate end.’’). In light of this meaning, the court found insufficient to waive sovereign immunity allegations that plaintiffs were held for approximately three months in a political prison where they allegedly ‘‘endured deplorable conditions while incarcerated, including urine-soaked mattresses, a cramped cell with substandard plumbing that they were forced to share with seven other inmates, a lack of medical care, and inadequate food,’’ and further ‘‘were kicked, clubbed and beaten by prison guards, and interrogated and subjected to physical, mental and verbal abuse.’’ Id. at 86 (internal quotations omitted). The Price court further found the complaint inadequate because it ‘‘says virtually nothing about the purpose of the alleged torture.’’ Id. at 94; see also Simpson v. Socialist People’s Libyan Arab Jamahiriya, 326 F.3d 230, 234 (D.C.Cir.2003) (finding allegations of forcibly removing passenger from cruise ship, holding passenger incommunicado and threatening her with death if she moved from her quarters did not rise to the level of torture under the FSIA and state a claim). [1, 2] Price considered the sufficiency of torture allegations when the defendants moved to dismiss the complaint for lack of subject matter jurisdiction. Price’s reasoning is equally instructive for determining whether a plaintiff in a default proceeding has established subject matter jurisdiction. When a court reviews unchallenged factual allegations on a motion to dismiss, the allegations are assumed to be true for purposes of assessing subject matter jurisdiction. Price, 294 F.3d at 93. Similarly, for the purposes of exam- 33 ining subject matter jurisdiction on a motion for entry of default under the FSIA, courts accept the plaintiffs’ factual allegations as true. Sisso v. Islamic Republic of Iran, 448 F.Supp.2d 76, 81 & n. 5 (D.D.C.2006) (reasoning on motion for entry of default in FSIA proceeding that court was ‘‘preclude[d] TTT at this stage of the litigation from making factual findings that are inconsistent with the allegations of the complaint’’ and explicitly accepted ‘‘all of plaintiffs’ factual allegations as true[.]’’). However, to establish subject matter jurisdiction, the allegations must be sufficiently detailed. At the pleadings stage, the Price court accordingly found inadequate the allegations before it, holding that plaintiffs’ complaint offers no useful details about the nature of the kicking, clubbing, and beatings that plaintiffs allegedly suffered. As a result, there is no way to determine from the present complaint the severity of plaintiffs’ alleged beatings—including their frequency, duration, the parts of the body at which they were aimed, and the weapons used to carry them out—in order to ensure that they satisfy the TVPA’s rigorous definition of torture. Price, 294 F.3d at 93. Beyond the pleadings stage, plaintiffs ‘‘have to prove the merits of their claims before they can obtain a default judgment ’’ and ‘‘the evidence they present will have to provide support’’ for the theories of liability they allege. Sisso, 448 F.Supp.2d at 79 n. 2. It follows that plaintiffs must provide sufficiently detailed proof of their allegations that DPRK agents tortured Reverend Kim in order to ensure that the conduct ‘‘satisf[ies] the TVPA’s rigorous definition of torture.’’ Price, 294 F.3d at 93. II. STANDARDS JUDGMENT FOR DEFAULT Default judgment against a foreign state shall be entered only where a plaintiff

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