50 356 FEDERAL SUPPLEMENT, 3d SERIES third party,’ ’’ and the plaintiff must identify a ‘‘ ‘nexus between what happened to [the hostage] in [the foreign state] and any concrete concession that [the foreign sovereign] may have hoped to extract from the outside world.’ ’’ Id. at 360 (quoting Price, 294 F.3d at 94). A plaintiff, however, ‘‘need not allege that the hostage taker had communicated its intended purpose to the outside world.’’ Id. Here, ample evidence has been presented that North Korea detained Otto and persisted in detaining him for political leverage with the United States. For instance, Fred and Cindy spoke ‘‘regularly with representatives from the Department of State as well as other senior United States officials, and were told on several occasions that Otto was being imprisoned in North Korea because North Korea wanted something from the United States, and that he would not be released until they had obtained that.’’ F. W. Decl. ¶ 15. Then-Secretary of State John Kerry, in particular, told Otto’s family in a meeting, after Otto’s trial and sentencing in North Korea, that ‘‘Otto is being held hostage by North Korea,’’ and ‘‘they will want something in exchange for releasing him.’’ Id.; see also H’rg Tr. (Rough) at 26 (F. W.); C. W. Decl. ¶ 19 (‘‘Several United States officials also told us that Otto was continuing to be held because North Korea wanted something from the United States and would not let him go until they got something in return.’’). The expert David Hawk, who has authored multiple reports on North Korean prison facilities for international organizations, explained that, ‘‘North Korea imprisoned and continued to imprison Otto in order to use his fifteen-year sentence of imprisonment to compel the United States to send a high level official to North Korea to increase its stature and to open a dialogue with North Korea during a time when the two countries were not communicatingTTTT’’ Hawk Expert Decl. ¶ 39; see also H’rg Tr. (Rough) at 102–03 (Expert David Hawk) (explaining Otto’s detention fit North Korea’s ‘‘pattern’’ of holding Americans hostage to serve its goal of ‘‘opening dialogue’’ with the United States). This view is corroborated by the expert Bob Collins, who confirmed that, ‘‘North Korea would view’’ Otto’s detention ‘‘as giving it leverage in its foreign policy goals, such as the ongoing development of its nuclear program during the time of Otto’s imprisonment.’’ Collins Expert Decl. ¶ 33; id. ¶ 34 (‘‘[North Korea] would have believed the nature of [Otto’s] crime as giving them a particularly strong ability to leverage their custody of him into achieving foreign policy goals with the United States as they could attribute the United States with a heinous affront to North Korean sovereignty.’’). Quite transparently, North Korea made the political leverage purpose of Otto’s detention clear when a spokesman for the North Korean Foreign Ministry stated after Otto’s death, ‘‘Warmbier is a victim of policy of ‘strategic patience’ of Obama who was engrossed in utmost hostility and negation against the DPRK and refused to have dialogue with the DPRK.’’ Hatch Decl., Ex. G (KCNA Article titled, ‘‘DPRK FM Spokesman Accuses U.S. of Slandering Humanitarian Measure’’). According to Professor Lee, for North Korea, hostage taking is ‘‘a very wellhoned craft’’ and ‘‘a tool of North Korea’s diplomacy,’’ designed ‘‘to compel the United States to negotiate from a position of weakness.’’ H’rg Tr. (Rough) at 121. ‘‘North Korea carefully plans the timing of events that it knows will have a substantial geopolitical impact.’’ Lee Expert Decl. ¶ 11. Otto’s case is no exception, as North Korea detained Otto ‘‘to deter the United States from responding either with military action or sanctions in the face of

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