The U.S. Supreme Court just ruled that “general corporate activity” does not in and of itself create jurisdiction for American federal courts to hear tort cases under the Alien Tort Statute (“ATS”). To plead facts sufficient to support a domestic application of the ATS, plaintiffs must allege more domestic conduct than the general corporate activity that is common to most corporations. In the case involving Nestlé USA and Cargill, two major U.S. corporations, six individuals from Mali alleged that they were trafficked into Ivory Coast as child slaves to produce cocoa. The American companies do not own or operate cocoa farms in Ivory Coast, but they do buy cocoa from farms located there and provide those farms with technical and…