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Rh regardless of any other conduct that occurred in U. S. territory.” RJR Nabisco, 579 U. S., at 337; see, e.g., WesternGeco, 585 U. S., at ___ (slip op., at 6–8); Nestlé, 593 U. S., at ___–___ (slip op., at 4–5); Morrison, 561 U. S., at 266–267, 271–273.

These holdings were not, as suggests, premised on this Court’s “first conclud[ing] (or assum[ing] without deciding) that the focus of the provision at issue was conduct.”  They were unambiguously part of this Court’s articulation of the two-step framework, and, in each case, these holdings came before we began analyzing the focus of the provisions at issue. For this reason, none of our cases has ever held that statutory focus was dispositive at step two of our framework. To the contrary, we have acknowledged that courts do “not need to determine [a] statute’s ‘focus’ ” when all conduct regarding the violations “ ‘took place outside the United States.’ ” RJR Nabisco, 579 U. S., at 337 (quoting Kiobel, 569 U. S., at 124); see, e.g., Nestlé, 593 U. S., at ___ (slip op., at 5) (“To plead facts sufficient to support a domestic application of the [Alien Tort Statute], plaintiffs must allege more domestic conduct than general corporate activity”). That conclusion, as well as the decisions applying it, are inexplicable under a focus-only standard. See.

Beyond straying from established precedent, a focus-only approach would create headaches for lower courts required to grapple with this new approach. For statutes (like this one) regulating conduct, the location of the conduct relevant to the focus provides a clear signal at both steps of our two-step framework. See RJR Nabisco, 579 U. S., at 335, 337. Under ’s standard, by contrast, litigants and lower courts are told that the step-two inquiry turns on the “ ‘focus’ ” alone, which (as we have said) “can be ‘conduct,’ ‘parties,’ or ‘interests’ that Congress sought to protect or regulate.” ; see WesternGeco, 585 U. S.,