1. at e-49-50 (The need to hold corporate bad actors materially accountable for bad acts regardless as to whether such acts take place was brought to the global fore in the aftermath to the 1984 Union Carbide gas leak;Justine Nolan;Agora: Reflections on KiobeI e-48,2014
2. 107 AJIL 829 at 835 citing Office of the High Commissioner on Human Rights, Guiding Principles on Business and Human Rights: Implementing the United Nations "Protect, Respect and Remedy" Framework, UNDoc. HR/PUB/11/04, princ. 7 cmt and princ;Robert Mccorquodale;Agora: Reflections on Kiobel,2011
3. Although here it should be noted that the current trend in Europe in the context of extrajudicial corporate accountability actions is to only apply the law of the situs state with some exceptions. McCorquodale at 847 citing Council Regulation (EC) No. 864;on the Law Applicable to Non-contractual Obligations,2007
4. Wuerth at 604 citing Khulumani v. Barclay Nat'l Bank Ltd;504 F.3d,2007