sentences:  For these reasons, the District Court, again found that Nigeria provided an adequate alternative forum.In finding that dismissal was also appropriate under for lack of subject matter jurisdiction, which the court mistakenly refers to as "Federal Rule of Civil Procedure 12(b)(6)", the court relied heavily upon "Sosa".Under "Sosa", the Alien Tort Claims Act creates no new causes of action but confers on federal courts the power to hear a narrow set of alien tort claims for violations of international law.