Ricardo Devengoechea inherited a historic collection of Simón Bolívar’s papers and personal effects, including governmental documents, correspondence, medals, epaulets, and a lock of Bolívar’s hair. He alleged that Venezuelan officials took the collection to Venezuela for inspection and purchase negotiations, then kept it for five years without paying or returning it. Venezuela invoked sovereign immunity and sought dismissal. The Eleventh Circuit affirmed the district court’s refusal to dismiss. The court held that the action fell within the Foreign Sovereign Immunities Act’s commercial-activity exception because Venezuela’s alleged conduct resembled that of a private buyer, occurred in connection with commercial activity outside the United States, and had a direct effect in the United States. The court rejected Venezuela’s effort to recast the dispute as an expropriation claim merely because an earlier complaint used that label. Federal pleading rules permit alternative theories, and the amended complaint controlled the jurisdictional analysis. The case was remanded for further proceedings.