Despite heightened attention in recent years to PMC [private military contractor] accountability, commentators have largely ignored PMCs’ potential tort liability under the Alien Tort Statute (“ATS,”…)…Ibrahim v. Titan Corp.28 and Saleh v. Titan Corp. provided the first opportunity for a U.S. court to hold PMC interrogators and translators accountable under the ATS for abusing individuals detained by the U.S. military at Abu Ghraib and other Iraqi prisons…With the increase of ATS litigation against PMCs, this Comment takes a close look at Ibrahim and Saleh, as well as case law suggesting that plaintiffs may indeed be able to hold PMCs accountable under the Alien Tort Statute in certain cases.