Last month, the U.S. Court of Appeals for the Second Circuit issued a decision in Khulumani v. Barclay National Bank and Ntsebeza v. Daimler Chrysler Corp. [now Daimler]... [T]he Second Circuit affirmed [US District Court] Judge Sprizzo's dismissal of claims under the Torture Victims Protection Act ("TVPA"), but reversed his dismissal of claims under the Alien Tort Claims Act ("ATCA")…. These particular ATCA suits are complex because the allegation was not that the defendants themselves committed torts, but that they aided and abetted the torts of others. Judge Sprizzo had held that "aiding and abetting" was not itself an actionable tort under the ATCA, but the Second Circuit, 2-1, disagreed.