Page:Abitron Austria GmbH v. Hetronic International, Inc..pdf/25

Rh Watch Company’s trade reputation” in the United States. Ibid. By contrast, the fact that Steele “affixed the mark ‘Bulova’ in Mexico City rather than here” was not “material.” Id., at 287.

Following Steele, the Courts of Appeals developed various tests, modeled after Steele’s facts, to address the Lanham Act’s extraterritorial reach. This Court also subsequently adopted a two-step framework for determining when a statute can apply extraterritorially to foreign conduct. That framework implements “a canon of statutory construction known as the presumption against extraterritoriality.” RJR Nabisco, Inc. v. European Community, 579 U. S. 325, 335 (2016). The presumption reflects the “longstanding principle of American law that legislation of Congress, unless a contrary intent appears, is meant to apply only within the territorial jurisdiction of the United States.” Morrison v. National Australia Bank Ltd., 561 U. S. 247, 255 (2010) (internal quotation marks omitted). That is, courts presume that, “in general, ‘United States law governs domestically but does not rule the world.’ ” RJR Nabisco, 579 U. S., at 335 (quoting Microsoft Corp. v. AT&T Corp., 550 U. S. 437, 454 (2007)).

Under this framework, the Court first asks “whether the presumption against extraterritoriality has been rebutted” by “a clear, affirmative indication that [the statute] applies extraterritorially.” RJR Nabisco, 579 U. S., at 337. If the presumption is not rebutted at that first step, the Court