We will hear argument first this morning in case 24-983, Havana docks versus Royal Caribbean Cruises.

Mr. Klinger.

Mr. Chief Justice, and may it please the Court, confiscated property is defined to include property Cuba seized control of.

As the Commission observed, Cuban officials physically occupied the dock facilities, making them confiscated

property. Stopping trafficking in such facilities locks them up as tainted until Cuba pays for

what it took. It's a takings remedy. Those are the core, I'm sorry, and it stops money flowing to Cuba in the interim. It's an anti-fencing remedy. Those are the core, I'm sorry, and it stops money flowing to Cuba in the interim.

It's an anti-fencing remedy as well.

Those are the core statutory objectives.

They require an ongoing remedy.

Because trafficking is in facilities, not property interests, term limits on interest have

no effect on the remedy's duration.

Instead, that remedy's duration is set out in the definition of confiscated and ends when the claim

is resolved or democracy comes to Cuba. That's also true of confiscated property is viewed instead

as an interest, the control of the docs taken and extinguished in 1960.

Title III is at the core of the foreign commerce power, yet the 11th Circuit shrunk Title III

by viewing the issue as though no confiscation had occurred.

But that gives little or no effect to future, contingent, life,

leasehold, and the many expired interests, including patents,

and places an open-for-business sign on property taken from Americans,

all contrary to why Title III was enacted.

The cruise lines acted in concert with Cuba,

and paid state security forces $130 million to make a billion dollars without seeking our authorization.

...