Taken as originally understood, the ATS does not support extraterritorial (let alone universal) jurisdiction for any conceivable violation of the shifting norms of customary international law. First, a statute directed at safe conduct violations suffered by “alien[s]” does not overcome the standard presumption against extraterritorial application; to the contrary, that limitation is inherent in the statute itself. Second, the ATS does not license the federal courts to “recognize” and enforce any manner of purported rights under international law, but only routine torts like assault, when in violation of safe conduct obligations. Third, because the common law of torts did not and does not provide for aiding and abetting liability, only primary tortfeasors (or their masters) may be subject to liability in ATS actions.