The U.S. Supreme Court’s recent decision in Kiobel v. Royal Dutch Petroleum1 upholding the dismissal of an Alien Tort Claims Act (ATCA) suit, left a great deal unanswered. The Kiobel decision did, however, limit the potential for future ATCA claims by applying a strong presumption against that statute’s extraterritorial application. There have since been some mixed appellate court decisions regarding the statute’s extraterritorial application,2 but a recent decision by the U.S. Court of Appeals for the Ninth Circuit may reflect a greater willingness by certain federal courts to accept ATCA suits against corporate defendants. In Doe v. Nestle USA, Inc. et al., the appellate court reversed the trial court’s decision to grant the corporate defendants’ motions to dismiss the plaintiffs’ ATCA claims, gave the plaintiffs the opportunity to re-plead their complaint in light of the presumption against the ATCA’s overseas application, and rather broadly construed still unresolved issues of corporate and “aiding and abetting” liability.