The United States exports its values structure in a variety of ways, including through the extraterritorial application of its laws. For instance, American firms must maintain Title VII standards abroad and are therefore prohibited from discriminating against employees anywhere in the world on the basis of sex, race, color, national origin, and religion. Compare this with the Alien Tort Statute, which was enacted in 1789 and authorizes foreign nationals to file civil suits in the United States against those who violate “the law of nations or a treaty of the United States.” In 2013, the U.S. Supreme Court held that the Alien Tort Statute (ATS) is subject to the traditional presumption against extraterritorial application and underscored the danger of judicial interference in foreign policy. It ruled that the ATS is presumed to cover only violations of international law occurring in the United States, unless the conduct overseas affects the United States “with sufficient force.” The court thus dismissed the underlying action brought by foreign plaintiffs against Royal Dutch Shell (a foreign MNE) for its alleged complicity in the Nigerian government’s execution of local activists.99 What public policy interests are likely to have motivated the Court’s decision? See Kiobel v. Royal Dutch Petroleum Co., 133 S. Ct. 1659 (2013).