The U.S. District Court for the Northern District of California has dismissed a lawsuit against Cisco Systems, Inc., for allegedly aiding the Chinese government in committing human rights abuses against members of the banned religious movement Falun Gong. The plaintiffs in Doe v. Cisco Systems, Inc., had alleged that Cisco helped China imprison, torture, and commit other abuses against Falun Gong members by designing China’s surveillance and security network, "Golden Shield," which Chinese authorities used to identify, track, locate, and apprehend those individuals, thereby violating the Alien Tort Statute and the Torture Victims Protection Act. The court dismissed the ATS claim on the ground that Cisco’s alleged actions did not sufficiently "touch and concern" the United States, and that there were insufficient allegations that Golden Shield played a substantial role in the abuses or that Cisco knew about the abuses. The court also dismissed the TVPA claim on the ground that the statute does not provide for aiding-and-abetting liability. The court’s ruling is good news for companies that may face lawsuits for doing business with repressive regimes, and continues a trend of narrow interpretations of the ATS following the Supreme Court’s seminal decision in Kiobel vs. Royal Dutch Petroleum. But the court’s interpretation of the ATS may be so restrictive as to render it vulnerable on appeal.