These brief comments address the future of corporate liability under the Alien Tort Statute (ATS) in the event that the Second Circuit’s ruling in Kiobel v. Royal Dutch Petroleum Co. does not prevail. In Kiobel, the Second Circuit made a bid to shut down corporate ATS liability altogether by holding that corporations do not owe duties under international law and thus cannot be sued under the ATS. Although I think that conclusion is correct as a technical matter, I recognize that it is not free from doubt, and its counterintuitive result (at least to an American audience) is further reason to doubt its ultimate viability. As a result, in considering the future of corporate ATS liability, it seems appropriate to look beyond Kiobel and consider whether other arguments might largely accomplish the same result.