Was there sufficient evidence that King had violated the FCPA?

Owl Securities and Investments, Ltd., hoped to develop a large port in Limon, Costa Rica. The project included docks, housing, recreational facilities, an airport, and more. Richard King was one of Owl’s largest investors, and Stephen Kingsley its CEO. The government charged King with attempting to bribe Costa Rican officials to obtain land and other concessions needed for their project. At trial, several of Owl’s officers, including Kingsley, Richard Halford, and Albert Reitz, testified against King. A jury convicted King of violating the FCPA. He received a 30-month sentence and a fine of $60,000. He appealed.