On 6 September 2022, the United States District Court for The District of Columbia granted the Republic of Zimbabwe’s motions to dismiss petitions to recognise two ICSID arbitration awards made made against it because the Court found – in both cases – that the Petitioners (the von Pezold family and their Zimbabwean companies) had failed to properly serve Zimbabwe pursuant to the strict requirements of § 1608(a)(3) of the Foreign Sovereign Immunities Act (“FSIA”).