The case of the day is Harvardsky Prumyslovy Holding A.S. v. Kozeny (N.Y. App. Div. 2014). In the 1990s, when Czech state-owned enterprises were being privatized, citizens were given vouchers to purchase shares in some of the firms. The vouchers could also be assigned to investment privatization funds, which would invest them on the citizen-assignor’s behalf. Viktor Kozeny was criminally prosecuted in the Municipal Court of Prague for engaging in a scheme in which he solicited investment in funds, including Harvardsky Prumyslovy Holding, and then “looted the [funds], diverting the funds of many Czech investors to a series of shell companies in Cyprus.” Kozeny, at the time of the prosecution, was in the Bahamas, and the government there refused to extradite him. He was therefore prosecuted in absentia, found guilty of fraud, and sentenced to imprisonment for ten years and restitution in the amount of approximately $410 million to the fund and its shareholders. The amount was, according to the judgment, “compensation for damage to the victim” under Section 228(1) of the Czech Code of Criminal Procedure.