MESKILL, Chief Judge: Appellants, all American citizens or residents, are more than one hundred “Names” in the Corporation of Lloyd’s (Lloyd’s). Loosely speaking, Names are investors in Lloyd’s syndicates, the entities that nominally underwrite insurance risk. For convenience we will refer to the syndicates as entities; although this is a disputed issue on appeal, we affirm on a different basis and therefore need not resol…
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