The Court below, Presbyterian Church of Sudan v. Talisman Energy, Inc., 582 F.3d 244 (2d Cir. 2009), addressed...questions about which the Circuits have disagreed. First, it held that international law provides the proper source of law for assessing accessory liability under the [Alien Tort Statute]. Second, it held that aiding and abetting requires a purpose to assist the underlying violation of international law...The Eleventh Circuit reached different results with respect to each question... [and] is correct...[T]the Second Circuit created new complicity liability standards that cannot be reconciled with ordinary federal common-law tort principles, and which would unjustifiably immunize from liability persons who knowingly assist the most heinous abuses...