In Kiobel, the Supreme Court could hold that the ATS has no extraterritorial application, it could severely limit its application, or it could maintain the status quo…[T]he emerging consensus is that even without the ATS, potential plaintiffs will have the capacity to submit their claims to other local or international tribunals. The most viable option…would be to pursue tort claims in local courts in the jurisdiction where the alleged torts occurred…Second, these cases could end up in the jurisdiction where the potential defendants reside or conduct their primary business activities, or in locations exercising universal jurisdiction or applying common law principles to bring civil or criminal charges…Cases such as Trafigura demonstrate the willingness of some States to extend their jurisdictional reach in the context of human rights violations or other series crimes. Even if the ATS option is lost, the international community has already been addressing these issues through new legislation and other measures…