On remand from the U.S. Supreme Court and in light of Kiobel v. Royal Dutch Petroleum Co., 133 S. Ct. 1659 (2013), the Ninth Circuit Court of Appeals has affirmed the trial court’s dismissal with prejudice of a lawsuit filed by plaintiffs seeking to hold a London-based company liable under the Alien Tort Statute (ATS) for the deaths of indigenous people on the island of Bougainville. Sarei v. Rio Tinto, PLC, Nos. 02-56256, -56390, 09-56381 (9th Cir., decided June 28, 2013). Additional details about Kiobel, in which the U.S. Supreme Court significantly narrowed the statute’s application, appear in the April 25, 2013, issue of this Report.