expression." Piracy and the high seas Article One provides that Congress shall have the power "[t]o define and punish Piracies and Felonies committed on the high Seas". Five sections in the Crimes Act "were devoted to the subject". Currie notes that the various piracy offenses "take an exceedingly broad view of what constituted piracy", but that "[f]rom a constitutional standpoint no harm was done, since all of the acts punished were felonious and Congress's power extended to all felonies on the high seas." "The principal provisions with respect to piracy were incorporated in section 8." Section 8 applied not only to the "high Seas", but also to "any river, haven, basin, or bay, out of the jurisdiction of any particular State". Currie notes a variety of constitutional theories which Congress might have espoused in order to justify this provision: "Whether Congress thought authority over such places included within the ostensibly narrower term 'high Seas', necessary and proper to the regulation of commerce or to the exercise of admiralty jurisdiction, or implicit in a central government responsible for external affairs is not clear." Currie also argues that the phrase "offence, which, if committed within the body of a county, would, by laws of the United States, be punishable with death" is vague. He suggests that it could refer to any federal law, to any state or federal law, or only to federal laws applicable to places under exclusive federal jurisdiction. Counterfeiting Article One provides that Congress shall have the power "[t]o provide for the Punishment of counterfeiting the Securities and current Coin of the United States." Currie argues that section 14's somewhat broad reading of the word "Securities" is fair enough. Currie suggests that "[n]othing was said of counterfeiting coins" because the United States Mint had not yet been established. Some members of the House, including Theodore Sedgwick of Massachusetts, spoke against the prescribing death penalty for counterfeiting, viewing it as too harsh. Crimes against the law of nations Article One provides that Congress shall have the power "[t]o define and punish ... Offenses against the Law of Nations." According to Currie: "No reliance on inherent on implied powers over foreign affairs was necessary to justify" sections 26 and 28 as each "plausibly described" offenses against the law of nations. Congress had also created a civil offense against the law of nations in the Alien Tort Statute of the Judiciary Act