U.S. federal law first adopted in 1789 that gives the federal courts jurisdiction to hear lawsuits filed by non-U.S. citizens for torts committed in violation of international law.

When the ATS was drafted in the 18th century, international law dealt primarily with regulating diplomatic relations between States and outlawing crimes such as piracy, however international law in the 21st century has expanded to include the protection of human rights. 

Inventor Joe Woodland drew the first bar code in sand in Miami Beach, decades before technology could bring his vision to life.  Joe Woodland said himself it sounded like a fairy tale: he had gotten the inspiration for what became the bar code while sitting on Miami Beach. He drew it with his fingers in the sand. What he was after was a code of some sort that could be printed on groceries and scanned so that supermarket checkout queues would move more quickly and stocktaking would be simplified. That such a technology was needed was not his idea: it came from a distraught supermarket manager who had pleaded with a dean at Drexel Institute of Technology in Philadelphia to come up with some way of getting shoppers through his store more quickly. The delays and the regular stocktaking were costing him his profits. The dean shrugged him off, but a junior postgraduate, Bernard "Bob" Silver, overheard and was intrigued. He mentioned it to Woodland, who had graduated from Drexel in 1947. Woodland was already an inventor, and he decided to take on the challenge.

It was here, at just after 8 a.m. on June 26, 1974, that the first item marked with the Universal Product Code (UPC) was scanned at the checkout of Troy’s Marsh Supermarket.

 In 1976, the father of a young man who had been tortured and killed in Paraguay while in police custody witnessed one of his son’s torturers walking the streets of Manhattan. The father called the INS, who arrested the former Paraguayan officer for overstaying his visitor’s visa. The father and sister then brought an ATS case against the officer, and in 1980, a U.S. federal court in New York upheld their claims, opening the door for future claims under the Alien Tort Statute.

Hara says that the company previously used barcodes to keep track of parts, but that the system was inefficient. “There were upward of ten barcodes on any one box,” Hara recounts. “Employees got tired of having to scan boxes multiple times, and this led us to come up with a code that would enable a large volume of information to be conveyed in a single scan.” From the need to keep better track of car parts sprang the QR code.

A QR code is characterized by a two-dimensional pattern of square black and white dots. With this pattern, it is possible to imbed 200 time more information than a standard barcode.

The codes can contain basic information like links to websites or large volumes of data consisting of over 4,200 alphanumeric characters that are encoded into the patterns. To access the information, a person needs only scan the QR code.

In the midst of the controversy surrounding the corporate and U.S. accountability suits, the Filartiga line of ATS cases was vindicated by the U.S. Supreme Court. In its 2004 ruling in Sosa v. Alvarez-Machain, the Court held that the ATS grants federal courts jurisdiction over claims based on specifically defined, universally accepted and obligatory norms of international law. In establishing this standard, the Court effectively gave the green light to the use of the ATS as a means of redress for severe human rights abuses.

Sosa did not sweep every kind of international law under the reach of the ATS, nor did it rule on which U.S. treaties are justiciable under the statute. The majority's discussion of treaties serves only to illuminate which sources courts can look to when determining what constitutes the law of nations, as the fact pattern of the case concerns only the latter. Another point of note is that Sosa only addresses suits between natural persons; claims where plaintiffs and/or defendants are entities (e.g., corporations, governments, etc.) are not part of the Court's holding. Finally, the Court does not address the asymmetry of rights, whereby alien plaintiffs enjoy a right under the ATS (i.e., federal rather than state jurisdiction over tort damages of any amount) that U.S. citizens do not.

With the above considerations in mind, the Court established a flexible framework for determining which torts constitute causes of action under the ATS. Four key principles underpin the framework: universality, obligatory nature, specificity, and prudential considerations.

On the eve of trial, the parties in Wiwa v. Shell agree to a $15 + MM settlement for all three of the lawsuits.

The Alien Tort Statute (ATS) does not permit lawsuits against corporations. Justice Anthony Kennedy authored the opinion for the 5-4 majority. The Court found that the original purpose of the ATS was to ensure that federal courts of the United States were available venues for foreign nationals alleging violations of international law and thereby to assuage potential foreign-relations issues. The Court reasoned that in this case, to allow the lawsuit to proceed would have the opposite policy effect, straining diplomatic relations with Jordan. If Congress wants to allow for lawsuits against foreign corporations in these types of circumstances, Congress should explicitly do so.

Justice Neil Gorsuch wrote a concurrence in which he concluded that there are two additional reasons the lawsuit should be dismissed—that the ATS is a jurisdictional statute that does not create a new cause of action and that federal courts should require a domestic defendant before hearing a lawsuit under the ATS.

Justice Sonia Sotomayor wrote a dissenting opinion in which Justices Ruth Bader Ginsburg, Stephen Breyer, and Elena Kagan joined. Justice Sotomayor wrote that the text, history, and purpose of the ATS support the conclusion that corporations may be sued under the law and that the Court's decision absolves corporations of responsibility for egregious human rights abuses.

CirclesX technology patent families extend to include crowdsourced legal blockchains as immutable structures to help solve legal claims across auto accident claims, Medicare Claims, health care claims, and product liability claims.

In many embodiments, an important feature of the method is
linking and synchronizing and associating the non-electronic codes with portable multifunction
devices over the multi-dimension code legal blockchain which transforms nonelectronic
objects into trackable objects along the multi-dimension code legal blockchain.