The Justice Against Sponsors of International Terrorism Act of 2016 (JASTA; 18 USC 2333) amended the ATA to include secondary civil liability for aiding and abetting, or conspiring to commit, acts of international terrorism. To recover under that section on an aiding and abetting claim, the plaintiff must show (1) the party the defendant aided committed an act of international terrorism that injured the plaintiff; (2) the defendant was generally aware of its role in third party’s terrorist activities at the time it provided assistance to the third party, and (3) the defendant knowingly and substantially assisted the act of terrorism that injured the plaintiff. In assessing the third element, the court should consider (1) the nature of the act encouraged, (2) the amount of assistance given by defendant, (3) defendant’s presence or absence at the time of the tort, (4) defendant’s relation to the principal, (5) defendant’s state of mind, and (6) the period of defendant’s assistance. Here, in one case, the court concluded that the plaintiff had not alleged facts sufficient to establish that Google had knowingly assisted ISIS in recruiting terrorists through its YouTube and other Internet postings. But held in another case sufficient allegations had been made that Google ignored manifold warnings that it was helping ISIS’ terrorist activities.