Ricardo Devengoechea, an Orlando collector, alleged that Venezuelan officials persuaded him to bring his collection of Simón Bolívar artifacts to Venezuela for inspection and then neither bought nor returned them. During his suit under the Foreign Sovereign Immunities Act, Venezuela underwent a regime change, its lawyers withdrew, and it ignored pretrial orders, so the district court held a bench trial without Venezuela and awarded Devengoechea more than $17.1 million. The Eleventh Circuit, in a substituted opinion, held that the trial in Venezuela’s absence was improper because any event leading to a default judgment against a foreign state is governed by section 1608(e) of the Act, which must be implemented through the procedures of Federal Rule of Civil Procedure 55. Relying on its decision in Compania Interamericana, the court explained that the Act protects foreign states from judgments based on procedural defaults, requiring entry of default, written notice at least seven days before a default hearing, and satisfactory evidence on every element of each claim. Because none of those steps occurred and the record did not show that the district court considered section 1608(e), the court vacated the judgment and remanded. Judge Rosenbaum dissented, arguing that Rule 55 default was unavailable after the pleading stage under Bass v. Hoagland, that the district court properly held a noticed trial in absentia, and that Devengoechea proved his claims in any event.