Issue: Whether, under Kiobel v. Royal Dutch Petroleum’s “touch and concern” test, courts must consider all connections Alien Tort Statute claims have to U.S. territory, as the U.S. Court of Appeals for the 4th, 9th, and 11th Circuits have held, or only the location of the alleged tort itself, as the U.S. Court of Appeals for the 2nd and 5th Circuits have held.
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