...1795 Opinion of the AG obviously affirmed expectations that the ATS is
extraterritorial, applying to conduct of U.S. citizens on the coast of Africa. Moxon and Bolchos also affirm
extraterritoriality when one recognizes the fact that foreign flag vessels are the equivalent of foreign territory under international law and tha conduct on such vessels is conduct in the territory of the flag, among other early cases. Adra was
extraterritorial and the landmark Filartiga case was
extraterritorial as have been so many cases post-Filartiga (especially Kadic, Presbyterian Church of the Sudan,...