ABITRON AUSTRIA GMBH V. HETRONIC INTERNATIONAL INC.

The Court held that the Lanham Act (the federal trademark statute) does not apply extraterritorially and that a domestic application of the statute requires use of the trademark in domestic commerce. Regarding the presumption against extraterritoriality more broadly, the majority emphasized that conduct related to a non-extraterritorial statute's focus must occur in the United States, even if the focus itself is not about conduct.

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The New (Old) Presumption Against Extraterritoriality

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Supreme Court Roundup (October Term 2022)

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