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In Kiobel v. Royal Dutch Petroleum,1 the U.S. Supreme Court further limited the reach of the 1789 Alien Tort Statute (ATS), precluding its application in so-called "foreign-cubed" cases—where neither plaintiffs, defendants nor any of the events giving rise to the claim have any connection with the United States. Since the Second Circuit’s 1980 decision in Filartiga v. Pena-Irala,2 the ATS has served as a vehicle for litigation in federal courts brought by litigants from many countries claiming injury as a result of violations of well-established international human rights law norms at the hand of foreign officials and their aiders and abetters. The April 17, 2013, Kiobel decision places in question the ATS’ continued utility as a vehicle for challenging human rights abuses occurring in other countries. After Kiobel, the courts will require, at the least, that "the claims touch and concern the territory of the United States."3

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