In 1982, a subsidiary of W. S. Kirkpatrick & Co. won a Nigerian Defense Ministry contract for the construction and equipment of an aeromedical center at a Nigerian Air Force base. Environmental Tectonics Corporation (Environmental), an unsuccessful bidder for the same contract, filed RICO and Robinson-Patman Act claims against Kirkpatrick. Environmental alleged that Kirkpatrick had won the contract by paying a 20 percent "commission" to bribe certain Nigerian officials. The parties agreed that the bribes, if paid, would violate Nigerian law. Was the trial court correct in holding that the act of state doctrine barred Environmental's claim?
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