the presumption against extraterritoriality has occurred over many decades in many courts of appeals and has produced a collection of tests for divining congressional intent that are complex in formulation and unpredictable in application. The results demonstrate the wisdom of the presumption against extraterritoriality. Rather than guess anew in each case, this Court applies the presumption in all cases, preserving a stable background against which Congress can legislate with predictable effects.” Stevens filed a partial concurrence, which Ginsburg joined, rejecting the overturning of the existing jurisprudence on section 10(b); at the same time, he held that in this particular case, the defendants should prevail, since both the plaintiffs and defendants were Australian, and the case would be better dealt with by the Australian court system – but unlike the majority, he would apply 10(b) to cases involving non-US securities, where there was a closer connection to the US (e.g. US plaintiffs). Aftermath The Dodd–Frank Wall Street Reform and Consumer Protection Act of July 21, 2010, in its section 929P(b), allowed the SEC and DOJ extraterritorial jurisdiction, but this interpretation remains contested in the courts. In its section 929Y, the Act commissioned the SEC to study extending the permission to private actors. The study indicated a number of options for action to be taken by Congress, which in varying degrees would mitigate the decision. In late 2010, Fabrice Tourre of Goldman Sachs asked for dismissal of an SEC suit against him based on the repercussions of the decision in this case, claiming his deals were outside the US and thus not subject to certain US laws. See also List of United States Supreme Court cases, volume 561 US corporate law Dodd–Frank Wall Street Reform and Consumer Protection Act Extraterritorial jurisdiction Notes External links Entry at SCOTUSBlog United States Supreme Court cases 2010 in United States case law United States securities case law United States Supreme Court cases of the Roberts Court National Australia Bank Extraterritorial jurisdiction