On December 18, 2019, the Supreme Court of the State of New York dismissed all of Plaintiffs’ claims in the action styled Guo Wengui, et al. v. Sam Nunberg, et al., Index No. 162069/2018 (N.Y. Sup. Ct. N.Y. Cnty.), seeking billions of dollars from Arkin Solbakken LLP client Dr. Bruno Wu, a prominent entrepreneur and philanthropist. The Court’s order was issued as a result of Dr. Wu’s motion to dismiss Plaintiffs’ Complaint, which argued, among other things, that the act of state doctrine barred all of Plaintiffs’ non-defamation claims, that the Court lacked jurisdiction over Dr. Wu with respect to Plaintiffs’ defamation claims, and that Dr. Wu never published any defamatory statements about Plaintiffs.