| http://www.w3.org/ns/prov#value | - While the Supreme Court recently issued its long-awaited first decision addressing the scope of the ATCA, Sosa v. Alvarez-Machain, it specifically left open the corporate actor question under the ATCA. To respond to this confusion, and to redress cases such as Flores, Congress and the Circuits must set a standard which makes individual corporate liability a threshold question, as in the Ninth Circ
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