Dynatec, Inc. $($a U$.$S$.$ corporation based in New York$)$ engages in oil drilling in Colombia. Indigenous Indian tribes finds that certain rivers and streams have become polluted as a result and that hunting and fishing are adversely affected. A U$.$S$.$ lawyer brings a lawsuit on behalf of the tribe in federal district court in New York. Dynatec wants the action dismissed, or at least not heard by the federal court in New York. The best bet for the case not to be heard in the federal court in New York would be for the Dynatec lawyer to:

a$.$

move for a stay pending arbitration.

b$.$

move for dismissal based on forum non conveniens.

c$.$

move to dismiss for lack of subject matter jurisdiction.

d$.$

move to dismiss for lack of personal jurisdiction.