doctrine to encompass the following crimes: genocide, crimes against humanity, war crimes and torture. In 2001, the Princeton Principles on Universal Jurisdiction, defined universal jurisdiction as: [C]riminal jurisdiction based solely on the nature of the crime, without regard to where the crime was committed, the nationality of the alleged or convicted perpetrator, the nationality of the victim, or any other connection to the state exercising such jurisdiction. CJA has drawn on the principle of universal jurisdiction to try cases in U.S courts and before the Spanish National Court. Since the 1998 prosecution of former Chilean dictator Augusto Pinochet, Spain has adopted universal jurisdiction over cases of severe violations of international human rights law. CJA has initiated criminal investigations with the Spanish court to prosecute human rights abuses in Guatemala and El Salvador. In a July 18, 2006 interview, CJA executive director, Pamela Merchant, made clear the connection between ATS litigation and broader universal jurisdiction efforts: [U]niversal jurisdiction is the endgame ... Here we're using the Alien Tort Statute, [elsewhere] we're using other vehicles, but there are crimes so outrageous that they should be prosecuted anywhere if the appropriate governments aren't doing it. Command responsibility Proponents of universal jurisdiction assert that real deterrence cannot be achieved until military and government officials are aware that they can be held individually accountable, not just for committing abuses, but for their failure to take reasonable action to stop others under their command from committing abuses. This claim is derived from the principle of command responsibility, the doctrine of complicity which provided the legal foundation for the Nuremberg Trials against senior Nazi war criminals. The command responsibility doctrine was enshrined in U.S. law by the U.S. Supreme Court decision In Re Yamashita (1946). Command responsibility is now an established theory of liability, thanks in part to the body of case law that has developed around CJA's litigation and the casework of other organizations pursuing similar strategies, notably the Center for Constitutional Rights and EarthRights International. Transitional justice Much of CJA's litigation and advocacy work is performed with survivors from countries still struggling to transition from an authoritarian past to a stable democratic present. Uncovering and seeking redress for human rights crimes is often a necessary component of a nation's emergence from civil strife and repression. Transitional justice denotes the process by which societies address the crimes of prior regimes as they move from a period