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[PDF] Esther Kiobel, et al. v. Royal Dutch Petroleum, et al. - Brief of amici curiae Washington Legal Foundation and Allied Educational Foundation in support of Respondents
In the absence of anything in the language or history of the ATS suggesting that Congress affirmatively desired that the ATS should apply to conduct in a foreign territory, the presumption has not been overcome – and the efforts of Nigerian citizens to apply the ATS to activities that took place in Nigeria should be rejected.