Section 922 of the Dodd-Frank Act, 15 U.S.C. § 78u-6, contains a provision that prohibits employers from retaliating against whistleblower employees who make certain protected disclosures. In Liu, the plaintiff employee sued Siemens under this provision, claiming that it demoted and eventually fired him in retaliation for his internal complaints concerning allegedly improper payments by Siemens employees to officials in North Korea and China. However, the plaintiff is a citizen and resident of Taiwan; he was employed by a Chinese subsidiary of Siemens, a German corporation; and he did not allege in his complaint that any of the relevant conduct occurred within U.S. territory. Following the Supreme Court’s 2010 decision in Morrison v. National Australia Bank Ltd., the Second Circuit applied the presumption that Congressional legislation is meant to apply only within the territorial jurisdiction of the United States unless a contrary intent appears, and that the mere listing of a foreign corporation’s securities on a U.S. exchange is not sufficient to overcome this presumption against extraterritoriality. The Second Circuit found no basis in the statute or in Liu’s arguments for concluding that Congress intended the statute to apply outside U.S. territory in a case such as his, where the whistleblower, his employer, and the other entities involved in the alleged wrongdoing were all based abroad, and the alleged retaliatory conduct also occurred abroad. The Second Circuit therefore concluded that the district court had properly dismissed the complaint on that ground.