We hasten to add that, although proof of a criminal violation under
sections 2339A or
2339B might satisfy the definition of international terrorism under
section 2333, such proof is not necessary to sustain a
section 2333 claim. As we discuss in the context of aiding and abetting, we believe Congress intended for civil liability for financing terrorism to sweep more broadly than the conduct described in
sections 2339A and
2339B. We also note that the district court seems to have inadvertently redefined the term “material” in the context of
sections 2339A and
2339B as meaning substantial or considerable. The statute itself defines “material support or resources” as “currency or other financial securities, financial services, lodging, training, safehouses, false documentation or identification, communications equipment, facilities, weapons, lethal substances, explosives, personnel, transportation, and other physical assets, except medicine or religious materials.”
18 U.S.C. § 2339A(b). Thus, the term relates to the type of aid provided rather than whether it is substantial or considerable. For civil liability,
section 2333 requires that the plaintiff be injured “by reason of” the act of international terrorism. Because we believe Congress intended to import standard tort law into
section 2333, causation may be demonstrated as it would be in traditional tort law. Congress has made clear, though, through the criminal liability imposed in
sections 2339A and
2339B, that even small donations made knowingly and intentionally in support of terrorism may meet the standard for civil liability in
section 2333. Congress' goal of cutting off funding for terrorism would be seriously compromised if terrorist organizations could avoid liability by simply pooling together small donations to fund a terrorist act.