dissenting:
When Dariush Elahi applied for and accepted $2.3 million from the United States Treasury under the Terrorism Risk Insurance Act of 2002 (TRIA), he relinquished the right to attach property at issue in claims against the United States before an international tribunal. See Pub.L. No. 107-297, § 201(d)(5)(B), 116 Stat. 2322, 2339. Iran’s Ministry of Defense (MOD), and the United States as amicus curiae, argue that Elahi has relinquished his right to attach the Cubic judgment because it is “at issue” in Iran’s Case B/61 before the United States-Iran Claims Tribunal.1 I agree.
Case B/61 involves the status and disposition of Iranian military property and assets situated in the United States. One of the pieces of military equipment in dispute in Case B/61 is the Air Combat Maneuvering Range (ACMR), which MOD purchased from Cubic on October 3, 1977. Because Iran has already recovered $2.8 million from Cubic for damages arising out of the 1977 Cubic contract, the United States is entitled to use the Cubic judgment as a setoff against any award in Case B/61.
Although the Cubic judgment will affect the amount of money damages the United States will have to pay, the majority concludes that the Cubic judgment is not “at issue” in Case B/61 and can be attached by Elahi. As a result, the government — if found liable in Case B/61 — will no longer have the benefit of the $2.8 million Cubic judgment that otherwise would be deducted by offset. Because the majority’s interpretation of “at issue” contradicts the term’s plain meaning and Congress’ intent in passing TRIA, I respectfully dissent.
I. TRIA’s Relinquishment Provision
By enacting TRIA in 2002, Congress expanded the class of judgment creditors eligible to receive payments from the United States Treasury for judgments awarded against “terrorist parties].” TRIA § 201(a). Sponsors expressed the hope that TRIA would provide American victims previously denied compensation, such as Elahi, with “some measure of justice.” 148 Cong. Rec. S11524-01, 11527 (daily ed. Nov. 19, 2002) (statement of Sen. Harkin).
However, TRIA’s justice comes at a cost. Those who receive partial compensation must agree to relinquish the right to execute or attach property “that is at issue in claims against the United States before an international tribunal or that is the subject of awards by such tribunal,” TRIA § 201(d)(5)(B), and recipients must sign an agreement stating:
I hereby relinquish ... all rights to execute against or attach property that *1038is at issue in claims against the United States before an international tribunal or that is the subject of awards by such tribunal.
I understand that the relinquishment that I make in the event of any pro rata distribution is irrevocable once the payment is credited to the bank account I have identified in this application.
See Payments to Persons Who Hold Certain Categories of Judgments Against Cuba or Iran, 68 Fed.Reg. 8077-02, 8081 (Feb. 19, 2003).
When Elahi accepted TRIA funds in April 2003, he knew that he risked waiving the right to attach the Cubic judgment. As early as 2002 MOD argued before the district court that the Cubic judgment “is at issue in Case B/61 between the United States and Iran in the Hague.” See Ministry of Defense & Support for Armed Forces of Islamic Republic of Iran v. Cubic Def. Sys., Inc., 236 F.Supp.2d 1140, 1146 (S.D.Cal.2002) (quoting MOD’s briefing). Although I am deeply sympathetic to Elahi and his family for their personal loss, relinquishment of the right to attach the Cubic judgment is part of the bargain Elahi struck by accepting funds from the United States treasury.
II. Plain Meaning of “At Issue”
This case presents a question of statutory interpretation. As such, the first step is determining “whether the language at issue has a plain and unambiguous meaning with regard to the particular dispute in the case.” Robinson v. Shell Oil Co., 519 U.S. 337, 340, 117 S.Ct. 843, 136 L.Ed.2d 808 (1997). For our purposes, the language at issue is “at issue.”
When determining the plain meaning of language, we may consult dictionary definitions. See Af-Cap, Inc. v. Chevron Overseas (Congo) Ltd., 475 F.3d 1080, 1088 (9th Cir.2007). Black’s Law Dictionary defines “at issue” as “[t]aking opposite sides; under dispute; in question.” Black’s Law Dictionary (8th ed.2004). Similarly, the American Heritage Dictionary of the English Language (4th ed.2000), defines “at issue” as “[i]n question; in dispute.” It is evident from these definitions that Congress selected a term with a relatively broad meaning. See Hegna v. Islamic Republic of Iran, 376 F.3d 485, 492 (5th Cir.2004) (rejecting narrow interpretation of “at issue”).2
The Cubic judgment is at issue before the Claims Tribunal because — under any scenario — the Tribunal must determine the effect of the judgment on the amount of liability owed by the United States. Iran has voluntarily pledged to offset the $2.8 million Cubic judgment against any award it wins against the United States in Case B/61. If Iran keeps its promise, that will affect the Claims Tribunal’s determination of the amount of damages the United States will have to pay Iran.
Significantly, even if Iran were to renege on its promise, the Cubic judgment would be at issue because the United States could then claim an entitlement to a setoff. Under Claims Tribunal precedent, a defending party may request a reduction of damages where the setoff arises from the same transaction or contract as the underlying claim. See Computer Sciences Corp. v. Gov’t of the Islamic Republic of Iran, 10 Iran-U.S.C.T.R. 269 (Chamber 1 *1039Apr. 16, 1986). The $2.8 million Cubic judgment — like Iran’s underlying claim— arises from the 1977 contract between Iran and Cubic for the ACMR equipment. Moreover, the United States could also argue that offset is mandated by the doctrine of judicial estoppel. See Raygo Wagner Equip. Co. v. Iran Express Terminal Corp., 2 Iran-U.S.C.T.R. 141 (Chamber 3 Mar. 18, 1983) (finding Iran judicially es-topped from asserting that Claims Tribunal lacked jurisdiction where it forwarded inconsistent position before American court).
Because the Claims Tribunal will have to consider the effect of the judgment on any award levied against the United States government, I must conclude that the Cubic judgment is “property that is at issue” before the Claims Tribunal.
III. Reading the Statute as a Whole
My conclusion is reinforced by reading TRIA as a whole. Because statutory provisions are not written in a vacuum, we should also examine TRIA’s purpose and various provisions to understand the meaning of “at issue.” See Carson Harbor Village, Ltd. v. Unocal Corp., 270 F.3d 863, 880 (9th Cir.2001) (en banc). There is no legislative history to guide us, but it is evident from the plain text of § 201 that TRIA’s relinquishment provision was intended to prevent victims of terrorism who accept money from the federal treasury from attaching, executing on or making claims against property that might otherwise be used by the United States to satisfy judgments imposed by international tribunals.
Acting on this understanding, other circuits have rebuffed attempts by applicants to attach Iranian property that might become the subject of an award against the United States before the Claims Tribunal. In Hegna v. Islamic Republic of Iran, 376 F.3d 226, 235 (4th Cir.2004), the Fourth Circuit held that a family that accepted payment under TRIA relinquished its right to attach former Iranian diplomatic properties located in Bethesda, Maryland. The court held that such properties were “at issue” before the Claims Tribunal because Iran filed claims against the United States alleging that the federal government unlawfully “fail[ed] to grant Iran custody of its diplomatic and consular properties in the United States.” Id. (citation and internal quotation marks omitted). Because Iran’s claim remained pending before the Claims Tribunal, the court concluded that “it would appear rather straight-forward that the Bethesda properties fall within the contours of the Hegnas’ relinquishment.” Id. In short, had the Hegnas succeeded in effecting the sale of the properties to satisfy the balance of their judgment against Iran, the United States would then have had to compensate Iran for the value of those properties (if found liable to Iran), in effect covering the funds paid to the Hegnas through their attachment. This is the very result Congress intended to avoid through the relinquishment proviso.
Although Elahi’s attachment involves cash rather than buildings, adherence to legislative intent results in the same outcome. Having already received TRIA funds from the United States treasury, Elahi should not be permitted to attach property that might otherwise be used to satisfy a judgment against the United States. As in Hegna, the only way to effectuate congressional intent is to prohibit Elahi from doing so.
IV. Iran’s “Concession”
Although the majority’s interpretation of “at issue” contradicts plain meaning and congressional intent, the majority is “per-sua[ded]” to hold in favor of Elahi because Iran “conceded” in briefing to the Claims *1040Tribunal that the Cubic judgment and Case B/61 do not share identically of subject matter. Op. at 1030-31. There are convincing reasons to be persuaded otherwise.
In its briefing to the Claims Tribunal, Iran argued against giving res judicata effect to the ICC’s adjudication of its claim against Cubic because:
[the ICC’s] case and the present one lack three identities (identity of object, identity of parties, and identity of subject matter) required for that purpose. The object of this litigation, unlike that in the ICC lawsuit, is the United States’ obligation under the Algiers Declarations to arrange for the transfer of the items to Iran. The opposing party in this Case is, obviously not a U.S. private company, but the United States’ Government. The subject-matter of this Case, at variance with the ICC action, is the losses suffered by Iran as a result of the United States’ non-export of Iranian properties.
However, Iran’s argument concerned the equitable doctrine of res judicata and therefore has little bearing on this court’s exercise in statutory interpretation. Even if Iran were correct that the subject matter of Case B/61 is at variance with the ICC arbitration, it does not follow that the Cubic judgment is not at issue in Case B/61. “At issue” is not synonymous with identity of subject matter, a distinction that Congress clearly understood when it drafted TRIA.
TRIA’s relinquishment provision prohibits applicants from attaching two different types of property: (1) property that is “the subject of’ resolved claims before an international tribunal; and (2) property that is “at issue” when claims remain pending. “[T]he use of different words or terms within a statute demonstrates that Congress intended to convey a different meaning for those words.” Sec. & Exch. Comm’n v. McCarthy, 322 F.3d 650, 656 (9th Cir.2003). By using the conceptually broader term “at issue,” it is evident that Congress did not intend to limit the relinquishment provision strictly to property that is the subject of a pending claim before the Claims Tribunal.
Thus, the majority’s rationale that the Cubic judgment is not at issue because Case B/61 addresses the federal government’s liability for failing to restore frozen assets (including the ACMR), whereas the Cubic judgment reflects Cubic’s liability for the non-delivery of the ACMR, is wide of the mark. See Op. at 1031. The majority’s observation is, of course, accurate but not dispositive of the relinquishment analysis. Because MOD’s claim against the United States is still pending, the relevant question is not whether the Cubic judgment and Case B/61 share the same parties, causes of action or even the same “subject,” but whether the Cubic judgment is “at issue” or “in question” in Case B/61. Because the Claims Tribunal will have to consider the impact of the Cubic judgment on the amount of liability owed by the United States, the answer to that question is yes.
By relying so heavily on Iran’s argument — made in a different context to another tribunal — the majority rests its analysis on a shaky foundation. TRIA itself— its text and purpose — offers much firmer ground for an exercise in statutory interpretation. Adherence to established doctrines of statutory construction leads to the conclusion that Elahi relinquished his right to attach the Cubic judgment. I therefore respectfully dissent.
. Neither party disputes that the United States-Iran Claims Tribunal is an "international tribunal” for purposes of TRIA's relinquishment provision. See Hegna v. Islamic Republic of Iran, 402 F.3d 97, 99 (2d Cir.2005); Hegna v. Islamic Republic of Iran, 380 F.03d 1000, 1008-09 (7th Cir.2004); Hegna v. Islamic Republic of Iran, 376 F.3d 485, 492 (5th Cir.2004).
. Like the majority, my analysis is guided by the plain meaning of "at issue." See Op. at 1031 n. 7. We part ways because the majority limits the term "property ... at issue” to property that is the subject of a merits determination before the Claims Tribunal. See id. However, an issue is "in question” or "at issue” in a dispute even if it is not the subject of a merits determination. The effect of the Cubic judgment on the financial liability of the United States will be raised and adjudicated; that is sufficient to put the property "in question.”