The commercial activity exception to the Foreign Sovereign Immunities Act ("FSIA") identifies three grounds for which a sovereign’s commercial activity will subject it to jurisdiction in U.S. courts. The third ground permits a party to overcome the statute’s presumption of immunity based upon a sovereign’s act performed in connection with commercial activity elsewhere which causes a "direct effect" in the United States. In Republic of Argentina v. Weltover, Inc., 504 U.S. 607 (1992), this Court determined that an effect is "direct" if it follows "as an immediate consequence of the defendant’s . . . activity." Id. at 618 (quoting Weltover, Inc. v. Republic of Argentina, 941 F.2d 145, 152 (2d Cir. 1991)) (ellipses in original). In so holding, this Court expressly rejected the notion that the commercial activity exception "contains any unexpressed requirement of ‘substantiality’ or ‘foreseeability.’" Id.