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[PDF] Esther Kiobel, et al. v. Royal Dutch Petroleum, et al. - Supplemental Brief of the Chamber of Commerce of the United States of America as Amicus Curiae in support of Respondents
The governing rule of decision is clear: “When a statute gives no clear indication of an extraterritorial application, it has none.” Morrison v. National Australia Bank Ltd., 130 S. Ct. 2869, 2878 (2010). None means none. Because the ATS provides no clear indication of extraterritorial application, that ends the inquiry. The ATS therefore does not apply to causes of action arising within the sovereign territory of other nations, regardless of whether the alleged tortfeasor is a citizen of, or has connections to, the United States. Because the Complaint here involves alleged torts occurring in Nigeria, the suit must be dismissed.