On July 7, 2023, a panel for the U.S. Court of Appeals for the Ninth Circuit in Doe I v. Cisco Systems gave new life to the Alien Tort Statute (ATS), 28 U.S.C. §1350. Enacted in 1789, the ATS establishes federal court jurisdiction and (has been read to authorize within limits a federal action in damages for aliens injured by violations of the law of nations, now called customary international law (CIL), or violations of a treaty.