Normally, statutes are not thought to apply in foreign territory...The Supreme Court has strongly reaffirmed this “presumption against extraterritoriality,” in Morrison v. National Australia Bank LLC (2010). One would think that, if anything, the presumption would be stronger in [Alien Tort Statute (ATS)] cases, many of which have no connection whatsoever to the U.S....However, the Kiobel plaintiffs argue that...the statute’s reference to “the law of nations” should be taken as an explicit rebuttal of the presumption. Since many violations of the law of nations take place extraterritorially (by definition, in the case of piracy), their argument goes, the presumption cannot apply. Two reasons support the application of the canon of interpretation against extraterritoriality to the ATS. First, precedent and policy show that the presumption applies in full to international law offenses – even to piracy. Second, there is another jurisdictional presumption that applies to the ATS, though not one that has thus far featured in the litigation.