If a foreign sovereign entity is subject to suit under one of the exceptions to immunity otherwise conferred by the Foreign Sovereign Immunities Act, the Act does not affect the substantive law governing the entity’s liability.  Instead, 28 USC 1606 provides that when not entitled to immunity, “the foreign state shall be liable in the same manner and to the same extent as a private individual under like circumstances.”  To achieve that result, the same conflict of laws rules that govern a private suit against a private party must also govern the suit against the foreign sovereign.  Hence, in this case, brought in a California court to recover a Nazi-expropriated painting held in a collection owned by the Spanish government, California’s ordinary conflict of laws rules apply, not any federal common law conflicts rule.