Law360, New York ( October 25, 2016, 10:25 AM EDT) -- Perlette Jura Dylan Mefford In recent years, the U.S. Supreme Court's transnational jurisprudence has dramatically impacted cross-border litigation, particularly lawsuits arising under the Alien Tort Statute. Daimler narrowed broad concepts of personal jurisdiction and Kiobel made clear that the presumption against extraterritoriality applies in ATS cases.[1] Now, the court's recent decision in RJR Nabisco Inc. v. European Community has finally put to rest the debate about whether Morrison's "focus" test applies to the question of extraterritoriality in ATS cases.[2] RJR confirms that, in determining whether the application of a statute is impermissibly extraterritorial, courts must look to the statute's "focus."[3] This ruling displaces decisions from other courts, which held that Kiobel did not adopt the "focus" test for ATS cases....