In Nestle v. Doe, a near-unanimous majority of the U.S. Supreme Court dealt yet another blow to plaintiffs seeking to bring lawsuits against corporations for violations of international law holding that mere "corporate activity" within the United States is not enough to satisfy the general presumption against the extraterritorial application of federal law. Nestle represents the third time since 2013 that the court has sharply limited the ability of plaintiffs to bring claims under the 1789 Alien Tort Statute (ATS), 28 U.S.C. §1350, which grants federal courts jurisdiction over torts by "aliens in violation of the law of nations …" The justices continue to disagree over what types of claims remain open under the ATS and declined to adopt a categorical rule prohibiting any ATS lawsuits against corporations.