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Cisco Systems, Inc. v. Doe · ¶101

For all these reasons, Sosa correctly held that courts may find implied private rights of action cognizable under the ATS, so long as they proceed with “great caution” and do not recognize causes of action dissimilar to the Blackstone three: that is, those “for violations of any international law norm with less definite content and acceptance . . . than the historical paradigms familiar when [the ATS] was enacted.” Id., at 728, 732.
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