Law360, New York (February 21, 2012, 1:42 PM ET) -- The U.S. Supreme Court’s 2010 decision in Morrison v. National Australia Bank Ltd. created a sea change in private securities litigation by sharply limiting the extraterritorial application of the securities laws while employing language suggesting skepticism of extraterritoriality more generally.

Since then, the lower federal courts have been reevaluating the extraterritorial applicability of other statutory causes of action, including Racketeer Influenced and Corrupt Organizations cases.[1] The Second Circuit’s recent decision in Eligio Cedeno v. Castillo, 10-3861-cv (2d Cir. Jan. 24, 2012), continues the post-Morrison trend of...