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226 United States Sovereign Debt: A Thought Experiment On Default And RestructuringU.S., do have a form of connection requirement for the applicabilityof an exception from immunity from execution. 159 The United Naingproperty which is for the time being in use or intended for use for commercialpurposes, shall not be subject to any process for the enforcement of a judgment orarbitration award or, in an action in rem, for its arrest detention or sale.”); State ImmunityAct 1979, §15(4) (Cap 313 1979) (Sing.) (“Paragraph (b) of subsection (2)does not prevent the issue of any process in respect of property which is for the timebeing in use or intended for use for commercial purposes.”); State Immunity Act,R.S.C. 1985, c. S-18, §12(1)(b) (Can.) (“property of a foreign state that is locatedin Canada is immune from attachment and execution . . . except where . . . (b)the property is used or is intended for a commercial activity;”); Foreign States ImmunitiesAct, Act 87 of 1981 §14(3) (S. Afr.) (“Subsection (1)(b) shall not preventthe issue of any process in respect of property which is for the time being in use orintended for use for commercial purposes.”).See also Nat’l Iranian Oil Co. Revenues from Oil Sales, 65 I.L.R. 215, 242 (F.R.G.Federal Constitutional Court 1983) (rejecting the requirement of a connection betweenthe claim and the property sought to be attached, noting that “[a] principleof international customary law forbidding a State where proceedings have beenbrought from taking measures of enforcement and safeguarding measures againstassets of a foreign State which have no connection with the substantive claim beingbrought, cannot be established at present.”); Condor & Filvem v. Nat’l ShippingCo. of Nigeria, 33 I.L.M. 593 (It. Constitutional Court 1992), sub nom Condor &Filvem v. Minister of Justice, 101 I.L.R. 394, 402 (It. Constitutional Court 1992) (“afurther restriction is not generally recognized . . . that there be a specific link withthe subject matter of the request . . . .”); Abbott v. Republic of S. Afr., 113 I.L.R. 413,426 (Spain Constitutional Court, Second Chamber 1992) (“it is not necessary thatthe property in respect of which execution is sought should be intended for the selfsameactivity jure gestionis as that which provoked the dispute. To hold otherwisewould be to render illusory the right to enforcement of judgments in cases like thepresent one, involving the dismissal of an embassy employee.”).159 The French Court of Cassation held that the property in question had to bethe subject matter of the claim in order to be attached, noting “immunity can beset aside in exceptional cases such as where the assets attached have been allocatedfor an economic or commercial activity of a private law nature, which has givenrise to the claim at issue.” Islamic Republic of Iran v. Eurodif, 77 I.L.R. 513, 515-16(Court of Cassation, First Civil Chamber 1984) (noting that in this case “the debtoriginated in the very funds which had been allocated for the implementation of theFranco-Iranian programme for the production of nuclear energy, whose repudiationby the Iranian party gives rise to the application.”). However, this holding mayhave been undermined by a more recent case. In 2001, a French Court of Appealallowed for attachment of property of a foreign State relying on the ground thatproperty was used or intended for use for commercial activity, but the court madeno mention of the connection between the property sought to be attached and theunderlying claim. Creighton Ltd. v. Minister of Qatar, Cour d’appel [CA] [regionalcourt of appeal] Paris, 1st ch. G, Dec. 12, 2001, reprinted in Revue de l’Arbitrage417, 418 (2003).