For a zombie doctrine, alien tort had a lively late summer. [In August]…U.S. judges handed down no fewer than five post-Kiobel rulings. And although alien tort plaintiffs see four rays of hope, their most ambitious claim of all took a stake through the heart…Explosive alien tort claims against KBR and Arab Bank each failed…for lack of a strong U.S. connection. However, both companies continue to face claims under a different federal statute…[In]…Balintulo v. Daimler…Judge Jose Cabranes fired the fatal bullet by concluding: “[I]f all the relevant conduct occurred abroad, that is simply the end of the matter under Kiobel.” It was a sad moment for corporate accountability, but I can't quibble with his reading of Kiobel…[P]laintiffs can draw constructive lessons from the courts’ high summer human rights spree…[and] should try to assert parallel claims under federal laws that are expressly extraterritorial…Of course, each is limited to its own narrow circumstances...