...the second circuit Court of Appeals in New York ruled on September 17th that corporations could not be held liable under the Alien Tort Claims Act for breaches of international law abroad...But the respite may be short-lived. Courts in other countries, such as the Netherlands and Britain, have recently become more active in punishing firms for misdeeds abroad and human-rights campaigners have taken note. John Ruggie, the special representative for the United Nations secretary-general on business and human rights, will wind up his six-year study with a report next year that could also lead to new restraints on corporations. [refers to Shell, Unocal (part of Chevron), Talisman, Dow Chemical]