JOSÉ A. CABRANES, Circuit Judge:

The question presented is whether to issue a writ of mandamus to resolve in favor of the defendants this long-lived litigation under the Alien Tort Statute ("ATS") — a statute, passed in 1789, that was rediscovered and revitalized by the courts in recent decades to permit aliens to sue for alleged serious violations of human rights occurring abroad. The statute was first deployed in 1980 against individual defendants alleged to have perpetrated crimes against humanity, and beginning in 1997, some courts have extended its reach to suits against corporate defendants as well. See Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111, 116 (2d Cir.2010), aff'd on other grounds, ___ U.S. ___, 133 S.Ct. 1659, 185 L.Ed.2d 671 (2013). We consider this question in light of the Supreme Court's recent decision that federal courts may not, under the ATS, recognize common-law causes of action for conduct occurring in another country.

In these putative class-action suits brought on behalf of those harmed by the decades-long South African legal regime known as "apartheid," the plaintiffs assert that the South African subsidiary companies of the named corporate defendants — Daimler, Ford, and IBM (the "defendants") — aided and abetted violations of customary international law committed by the South African government.1 In short, the plaintiffs claim that these subsidiary companies sold cars and computers to the South African government, thus facilitating the apartheid regime's innumerable race-based depredations and injustices, including rape, torture, and extrajudicial killings.

The plaintiffs brought these suits over ten years ago in federal court under the ATS, which confers federal jurisdiction over "any civil action by an alien for a tort only, committed in violation of the law of nations or a treaty of the United States." 28 U.S.C. § 1350. Although the plaintiffs did not claim that any of the South African government's alleged violations of the law of nations2 occurred in the United States, at the time they filed their complaint they assumed (as did most American courts at that time3) that no such geographical connection was necessary. Based, in part, on that assumption, the United States District Court for the Southern District of New York (Shira A. Scheindlin, Judge)4 denied a motion to dismiss by the defendants, and allowed the suits to proceed. See In re South African Apartheid Litig., 617 F.Supp.2d 228, 246, 296 (S.D.N.Y.2009).

Although parties usually cannot appeal while district court proceedings are ongoing, the defendants sought immediate review of the District Court's denial of their motion to dismiss in this Court, first through a motion to certify an interlocutory appeal, which the District Court denied, and thereupon through either a writ of mandamus or under the "collateral order" doctrine5 — both of which permit immediate appellate review of certain types of particularly important decisions by a district court. In pursuing appellate review, the defendants claimed (1) that the case should be dismissed because it threatened significant United States foreign-policy interests, as explained in a statement of interest filed by the U.S. government; (2) that the jurisdiction conferred by the ATS does not permit suits against corporations or apply to acts committed outside of the United States; and (3) that the District Court erroneously imposed accessorial liability. We then granted the defendants' motion for a stay of all proceedings, putting the District Court proceedings on pause while we considered this case.

Now on appeal for over four years, this case has been overtaken by recent events. Most significantly, the Supreme Court held, as a matter of United States law, that federal courts may not, under the ATS, recognize common-law causes of action for conduct occurring in the territory of another sovereign. Kiobel v. Royal Dutch Petroleum Co., ___ U.S. ___, 133 S.Ct. 1659, 1668-69, 185 L.Ed.2d 671 (2013).6 Additionally, the South African government — which had previously opposed the suits because they "interfere[d] with the policy embodied by its Truth and Reconciliation Commission," Sosa v. Alvarez-Machain, 542 U.S. 692, 733 n. 21, 124 S.Ct. 2739, 159 L.Ed.2d 718 (2004) — reversed its position in September 2009 after a change in governmental leadership. After this series of twists and turns, the parties submitted supplemental briefing, and we have now reached a decision.

The opinion of the Supreme Court in Kiobel plainly bars common-law suits, like this one, alleging violations of customary international law based solely on conduct occurring abroad. Because of that unambiguous holding, the defendants will be able to obtain their desired relief (dismissal of all claims) in the District Court through a motion for judgment on the pleadings, without resort to a writ of mandamus. The defendants' request for mandamus relief is therefore denied. For the same reason, we need not consider the defendants' argument under the collateral order doctrine. Instead, we vacate our stay on the District Court proceedings so that the defendants may move for judgment on the pleadings. We reserve the question whether we have jurisdiction under the collateral order doctrine and hold the putative appeal under that doctrine in abeyance pending further notice from the parties.

I. Background

A. The Pleadings

These consolidated cases come to us as a continuation of litigation on which the District Court, this Court, and even the Supreme Court, have already spoken at length. See Part I.B., post. In the latest iteration of pleadings, which have been amended twice, the plaintiffs assert that the South African subsidiaries of the various corporate defendants aided and abetted in violations of customary international law during the repressive "apartheid" legal regime in South Africa. The District Court summarized these allegations as follows:

In re South African Apartheid Litig., 617 F.Supp.2d at 241-43.

B. Procedural History

"The tortuous procedural history of these cases dates back to the filing of complaints in 2002." In re South African Apartheid Litig., 624 F.Supp.2d 336, 338 (S.D.N.Y.2009).7 As relevant here, Judge Sprizzo, then presiding, dismissed the plaintiffs' claims under the ATS for lack of subject-matter jurisdiction, holding that the plaintiffs had not alleged a violation of "well-accepted and clearly-defined" norms of customary international law. In re South African Apartheid Litig., 346 F.Supp.2d 538, 546, 548 (S.D.N.Y.2004). We reversed that judgment in part, explaining in a per curiam opinion that "a plaintiff may plead a theory of aiding and abetting liability" under the ATS, Khulumani v. Barclay Nat'l Bank Ltd., 504 F.3d 254, 260 (2d Cir.2007) (per curiam), but we declined to reach other arguments, and instead permitted the plaintiffs to replead, id. at 260-61.8 After the defendants sought a writ of certiorari, the Supreme Court affirmed our decision for want of a quorum. See Am. Isuzu Motors, Inc., v. Ntsebeza, 553 U.S. 1028, 128 S.Ct. 2424, 171 L.Ed.2d 225 (2008) (Mem.).

On remand, the plaintiffs filed an amended complaint, this time naming only eight defendants.9 With the exception of one defendant that contested personal jurisdiction, the defendants then filed a joint motion to dismiss on various grounds, including doctrines of case-specific deference and international comity, lack of jurisdiction over corporations under the ATS, lack of extraterritorial reach for causes of action under the ATS, and the absence of aiding-and-abetting liability under the federal common law, as developed pursuant to Sosa v. Alvarez-Machain, 542 U.S. 692, 124 S.Ct. 2739, 159 L.Ed.2d 718 (2004). Judge Scheindlin, to whom the case was assigned following the death of Judge Sprizzo, rejected each of these arguments, and held that the suit could proceed on an agency theory, under which the corporate defendants could be held liable for the actions of their South African subsidiaries.10 See In re South African Apartheid Litig., 617 F.Supp.2d at 274-76. She explained that the South African subsidiary companies could be liable as accessories based on their knowledge that their dealings with the South African government facilitated the many evils of apartheid, even if the companies did not intend their assistance to have that effect.11 Id. at 259-62. Following the District Court's denial of certification, see In re South African Apartheid Litig., 624 F.Supp.2d 336 (S.D.N.Y.2009), the defendants brought this petition for a writ of mandamus, and a putative appeal under the collateral order doctrine, arguing that "the District Court's denial of dismissal should be reversed, and the cases remanded with instructions to dismiss the complaints." Defendants' Br. 59.12

We initially heard argument on a variety of preliminary motions on September 1, 2009. Only a day after argument, we received a letter from the South African government reversing its earlier position and declaring that it was "now of the view that [the United States District Court for the Southern District of New York] is an appropriate forum to hear the remaining claims of aiding and abetting in violation of international law." See Letter of Jeffrey Thamsanqa Radebe, Minister of Justice and Constitutional Development, Sept. 2, 2009; see also Sosa, 542 U.S. at 733 n. 21, 124 S.Ct. 2739 (explaining the South African government's prior position). We then stayed the District Court proceedings13 and ordered a limited remand to that Court "for the sole purpose of permitting defendants to move to certify an interlocutory appeal" on the question whether the ATS recognizes corporate liability. Order of Dec. 18, 2009. The District Court denied certification, explaining that although the question of corporate liability under the ATS was "a controlling issue of law" that "could materially advance the ultimate termination of this litigation," that question was "long-settled ... in this Circuit," with "no substantial ground for disagreement." In re South African Apartheid Litig., 2009 WL 5177981, at *2 (S.D.N.Y. Dec. 31, 2009) (quotation marks omitted).

Less than a year later, this Court (in a separate case) held that "the Alien Tort Statute does not provide subject matter jurisdiction over claims against corporations" based on asserted violations of customary international law. Kiobel v. Royal Dutch Petroleum Co., 621 F.3d 111, 149 (2d Cir.2010), reh'g en banc denied, 642 F.3d 379 (2d Cir.2011). The Supreme Court granted certiorari and, after reargument,14 affirmed our judgment on different grounds, holding that federal courts may not, under the ATS, recognize common-law causes of action for conduct occurring in the territory of another sovereign. Kiobel v. Royal Dutch Petroleum Co., ___ U.S. ___, 133 S.Ct. 1659, 1668-69, 185 L.Ed.2d 671 (2013). With respect to the present suit, we then requested, and have now received, supplemental briefing from the parties.

II. Discussion

The defendants seek a writ of mandamus under the All Writs Act, 28 U.S.C. § 1651,15 and, in the alternative, argue that we have appellate jurisdiction under the collateral order doctrine, see Mohawk Indus., Inc. v. Carpenter, 558 U.S. 100, 106-07, 130 S.Ct. 599, 175 L.Ed.2d 458 (2009) (citing Cohen v. Beneficial Indus. Loan Corp., 337 U.S. 541, 546, 69 S.Ct. 1221, 93 L.Ed. 1528 (1949)). The defendants further argue that, if we do have jurisdiction under the collateral order doctrine to consider the District Court's decision not to dismiss the suit based on case-specific deference or international comity, see Sosa, 542 U.S. at 733 n. 21, 124 S.Ct. 2739, we may also recognize any defect in subject-matter jurisdiction, see In re Methyl Tertiary Butyl Ether Prods. Liability Litig., 488 F.3d 112, 122 (2d Cir.2007). We address these arguments in turn.

A. Writ of Mandamus

i.

As a general matter, denials of a motion to dismiss are not appealable as "final decisions" of the district courts under 28 U.S.C. § 1291.16 See Catlin v. United States, 324 U.S. 229, 236, 65 S.Ct. 631, 89 L.Ed. 911 (1945). Nonetheless, federal procedural law provides two "discretionary review mechanisms" that "serve as useful `safety valve[s]' for promptly correcting serious errors." Mohawk Indus., 558 U.S. at 111, 130 S.Ct. 599 (quoting Digital Equipment Corp. v. Desktop Direct, Inc., 511 U.S. 863, 883, 114 S.Ct. 1992, 128 L.Ed.2d 842 (1994)) (alteration in original). First, a district court may certify an appeal pursuant to 28 U.S.C. § 1292(b) when it is "of the opinion that [the relevant] order involves a controlling question of law as to which there is substantial ground for difference of opinion and that an immediate appeal from the order may materially advance the ultimate termination of the litigation." 28 U.S.C. § 1292(b). When a ruling satisfies these criteria and "involves a new legal question or is of special consequence," then the district court "should not hesitate to certify an interlocutory appeal." Mohawk, 558 U.S. at 111, 130 S.Ct. 599. The relevant Court of Appeals may then, "in its discretion, permit an appeal to be taken from such order."17 28 U.S.C. § 1292(b).

If a district court refuses certification, or certification is not otherwise available, however, then a party may petition for a writ of mandamus — "a drastic and extraordinary remedy reserved for really extraordinary causes." Cheney v. U.S. Dist. Ct. for D.C., 542 U.S. 367, 380, 124 S.Ct. 2576, 159 L.Ed.2d 459 (2004) (internal quotation marks omitted); see also Will v. United States, 389 U.S. 90, 107, 88 S.Ct. 269, 19 L.Ed.2d 305 (1967) (noting that the writ of mandamus is one of "the most potent weapons in the judicial arsenal"); note 15, ante (common-law remedy codified in the All Writs Act). Three conditions circumscribe use of the writ:

Cheney, 542 U.S. at 380-81, 124 S.Ct. 2576 (alternations, internal quotation marks, and citations omitted). Mandamus relief is appropriate "in extraordinary circumstances," when, for example, a district court's order "amounts to a judicial usurpation of power or a clear abuse of discretion, or otherwise works a manifest injustice." Mohawk Indus., 558 U.S. at 111, 130 S.Ct. 599 (alteration and internal quotation marks omitted).18

Two aspects of ATS jurisprudence, however, urge greater appellate oversight through use of mandamus in appropriate cases. First, ATS suits often create particular "risks of adverse foreign policy consequences," Sosa, 542 U.S. at 728, 124 S.Ct. 2739, obliging courts to be "particularly wary of impinging on the discretion of the Legislative and Executive Branches in managing foreign affairs," id. at 727, 124 S.Ct. 2739. This risk of treading into matters within the province of other branches of government, and intruding into delicate areas of intergovernmental relations, warrants closer appellate scrutiny through supervisory mandamus review. See Cheney, 542 U.S. at 380-82, 124 S.Ct. 2576. Appellate courts have therefore been less hesitant to issue the writ when a lower-court decision threatens to affect the foreign policy of the United States. See, e.g., Ex parte Republic of Peru, 318 U.S. 578, 586, 63 S.Ct. 793, 87 L.Ed. 1014 (1943); In re Austrian, German Holocaust Litig., 250 F.3d 156, 163-65 (2d Cir.2001); Abelesz v. OTP Bank, 692 F.3d 638, 651 (7th Cir.2012). Second, and relatedly, the ATS places federal judges in an unusual lawmaking role as creators of federal common law. See Sosa, 542 U.S. at 724-25, 124 S.Ct. 2739. This exercise of authority by federal courts elevates "the danger of unwarranted judicial interference in the conduct of foreign policy," Kiobel, 133 S.Ct. at 1664, again warranting greater appellate oversight, see Cheney, 542 U.S. at 380-82, 124 S.Ct. 2576. In sum, a ruling that raises substantial questions of judicial power under the ATS and threatens to affect significant American foreign policy objectives cannot be insulated from immediate review simply because a lower court refuses to certify the order for appeal.

Such concerns are present here. In addition to the federal common-law aspect of these ATS suits, the United States government filed a statement of interest on October 30, 2003, articulating its position that "continued adjudication of [these] matters risks potentially serious adverse consequences for significant interests of the United States."19 Def. App'x 254. The statement of interest further explains:

Id. at 255-56. Such important foreign policy interests as those raised here cannot be vindicated by waiting until final judgment.

Nonetheless, we need not wade into the merits of the defendants' various arguments, because we are not persuaded that mandamus is the only "adequate means to attain the relief" that they desire. For the reasons explained in the following section, see Part II.A.ii., and in light of the Supreme Court's holding in Kiobel that federal courts may not, under the ATS, recognize common-law causes of action for conduct occurring in the territory of another sovereign, Kiobel, 133 S.Ct. at 1668-69, defendants can seek the dismissal of all of the plaintiffs' claims, and prevail, prior to discovery, through a motion for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure.20 Mandamus with respect to any of the defendants' various claims of error is, therefore, simply unnecessary in light of the Supreme Court's clear guidance that claims based on conduct occurring solely abroad cannot be adjudicated under the ATS.21

ii.

As we have now made clear, Kiobel forecloses the plaintiffs' claims because the plaintiffs have failed to allege that any relevant conduct occurred in the United States. The plaintiffs resist this obvious impact of the Kiobel holding on their claims. The Supreme Court's decision, they argue, does not preclude suits under the ATS based on foreign conduct when the defendants are American nationals, or where the defendants' conduct affronts significant American interests identified by the plaintiffs. See Plaintiffs' Letter Br. at 6-13. Curiously, this interpretation of Kiobel arrives at precisely the conclusion reached by Justice Breyer, who, writing for himself and three colleagues, only concurred in the judgment of the Court affirming our decision to dismiss all remaining claims brought under the ATS. See Kiobel, 133 S.Ct. at 1671 (Breyer, J., concurring). The plaintiffs' argument, however, seeks to evade the bright-line clarity of the Court's actual holding — clarity that ensures that the defendants can obtain their desired relief without resort to mandamus. We briefly highlight why the plaintiffs' arguments lack merit.

a.

The Supreme Court's Kiobel decision, the plaintiffs assert, "adopted a new presumption that ATS claims must `touch and concern' the United States with `sufficient force' to state a cause of action." Plaintiffs Letter Br. 6 (quoting Kiobel, 133 S.Ct. at 1669). The plaintiffs read the opinion of the Court as holding only that "mere corporate presence" in the United States is insufficient for a claim to "touch and concern" the United States, but that corporate citizenship in the United States is enough. Id. at 11 ("[I]nternational law violations committed by U.S. citizens on foreign soil `touch and concern' U.S. territory with `sufficient force' to displace the Kiobel presumption."). Reaching a conclusion similar to that of Justice Breyer and the minority of the Supreme Court in Kiobel, the plaintiffs argue that whether the relevant conduct occurred abroad is simply one prong of a multi-factor test, and the ATS still reaches extraterritorial conduct when the defendant is an American national. Id. at 8-11.

We disagree. The Supreme Court expressly held that claims under the ATS cannot be brought for violations of the law of nations occurring within the territory of a sovereign other than the United States. Kiobel, 133 S.Ct. at 1662, 1668-69. The majority framed the question presented in these terms no fewer than three times22; it repeated the same language, focusing solely on the location of the relevant "conduct" or "violation," at least eight more times in other parts of its eight-page opinion23; and it affirmed our judgment dismissing the plaintiffs' claims because "all the relevant conduct took place outside the United States," id. at 1669. Lower courts are bound by that rule and they are without authority to "reinterpret" the Court's binding precedent in light of irrelevant factual distinctions, such as the citizenship of the defendants.24 See Agostini v. Felton, 521 U.S. 203, 237-38, 117 S.Ct. 1997, 138 L.Ed.2d 391 (1997); see also Seminole Tribe of Fla. v. Florida, 517 U.S. 44, 66-67, 116 S.Ct. 1114, 134 L.Ed.2d 252 (1996). Accordingly, if all the relevant conduct occurred abroad, that is simply the end of the matter under Kiobel.

In the conclusion of its opinion, the Supreme Court stated in dicta that, even when claims brought under the ATS "touch and concern the territory of the United States, they must do so with sufficient force to displace the presumption against extraterritorial application."25 Kiobel, 133 S.Ct. at 1669 (citing Morrison v. Nat'l Austl. Bank Ltd., ___ U.S. ___, 130 S.Ct. 2869, 2883-88, 177 L.Ed.2d 535 (2010)). As the Court observed in Morrison, "the presumption against extraterritorial application would be a craven watchdog indeed if it retreated to its kennel whenever some domestic activity is involved in the case." 130 S.Ct. at 2884. But since all the relevant conduct in Kiobel occurred outside the United States-a dispositive fact in light of the Supreme Court's holding-the Court had no reason to explore, much less explain, how courts should proceed when some of the relevant conduct occurs in the United States.26

b.

The plaintiffs also assert that "the Kiobel presumption is displaced here" because of the compelling American interests in supporting the struggle against apartheid in South Africa. Plaintiffs' Letter Br. 11. These case-specific policy arguments miss the mark. The canon against extraterritorial application is "a presumption about a statute's meaning." Morrison, 130 S.Ct. at 2877 (emphasis supplied). Its "wisdom," the Supreme Court has explained, is that, "[r]ather than guess anew in each case, we apply the presumption in all cases, preserving a stable background against which Congress can legislate with predictable effects." Id. at 2881 (emphasis supplied). For that reason, the presumption against extraterritoriality applies to the statute, or at least the part of the ATS that "carries with it an opportunity to develop common law," Sosa, 542 U.S. at 731 n. 19, 124 S.Ct. 2739, and "allows federal courts to recognize certain causes of action," Kiobel, 133 S.Ct. at 1664. In order "to rebut the presumption, the ATS [i.e., the statute] would need to evince a clear indication of extraterritoriality." Id. at 1665 (quotation marks omitted). Applying this approach in Kiobel, the Supreme Court held as a matter of statutory interpretation that the implicit authority to engage in common-law development under the ATS does not include the power to recognize causes of action based solely on conduct occurring within the territory of another sovereign.27 In all cases, therefore the ATS does not permit claims based on illegal conduct that occurred entirely in the territory of another sovereign. In other words, a common-law cause of action brought under the ATS cannot have extraterritorial reach simply because some judges, in some cases, conclude that it should.

c.

Finally, the plaintiffs argue that the defendants "took affirmative steps in this country to circumvent the sanctions regime, though discovery would be necessary to determine the full scope of such U.S.-based conduct." Plaintiffs' Letter Br. 13. Without additional explanation, the plaintiffs refer to various paragraphs in the complaints asserting that the American defendants continued to supply the South African government with their products, notwithstanding various legal restrictions against trade with South Africa. See Balintulo Compl. ¶¶ 246-50 (Ford), App'x 494-95; id. ¶¶ 196, 198, 212(IBM), App'x 483, 486; Ntsebeza Compl. ¶ 128 (Ford), App'x 199; id. ¶¶ 139-41(IBM), App'x 202-03.

None of these paragraphs, however, ties the relevant human rights violations to actions taken within the United States. The complaint alleges only vicarious liability of the defendant corporations based on the actions taken within South Africa by their South African subsidiaries. See In re South African Apartheid Litig., 617 F.Supp.2d 228, 275 (S.D.N.Y.2009) ("[A]llegations [of an agency relationship] are sufficiently plausible to allow this claim to proceed on a theory of vicarious liability."). Because the defendants' putative agents did not commit any relevant conduct within the United States giving rise to a violation of customary international law — that is, because the asserted "violation[s] of the law of nations occurr[ed] outside the United States," Kiobel, 133 S.Ct. at 1669 — the defendants cannot be vicariously liable for that conduct under the ATS.28

In sum, the Supreme Court's holding in Kiobel plainly bars the plaintiffs' claims, and the defendants will therefore be able to obtain relief in the District Court by moving for judgment on the pleadings. Accordingly, mandamus relief is denied.

B. Collateral Order Doctrine

The defendants also assert that the district court's order denying their motion to dismiss is a "collateral order," subject to immediate appellate review. In contrast to the "discretionary review mechanisms" of certification and mandamus, Mohawk Indus., 558 U.S. at 111, 130 S.Ct. 599, collateral order appeals are taken "as of right," id. at 112, 130 S.Ct. 599, and do not depend on an "`individualized jurisdictional inquiry,'" id. at 107, 130 S.Ct. 599 (quoting Coopers & Lybrand v. Livesay, 437 U.S. 463, 473, 98 S.Ct. 2454, 57 L.Ed.2d 351 (1978)). The parties have presented strong arguments on each side regarding the immediate appealability of the District Court's order under the collateral order doctrine,29 but we need not confront that question now. The Supreme Court's decision in Kiobel, among other developments in ATS jurisprudence during the past four years, plainly forecloses the plaintiffs' claims as a matter of law. See Part II.A.ii, ante.

In these circumstances, the interests of judicial economy, and of the parties, are best served by holding this putative appeal under the collateral order doctrine in abeyance and enabling the District Court to consider a motion for judgment on the pleadings to dismiss the plaintiffs' remaining claims.30 See, e.g., Authors Guild, Inc. v. Google Inc., 721 F.3d 132 (2d Cir.2013); In re Sims, 534 F.3d at 127. The parties can then inform this Court, when appropriate, that this matter has been rendered moot.

CONCLUSION

To summarize:

Because the Kiobel decision, combined with the opportunity to move for dismissal in the District Court, provides an adequate ground for dismissing all remaining claims, the defendants' petition for a writ of mandamus is DENIED. The stay placed by this Court on proceedings in the District Court is hereby VACATED. Proceedings in the District Court may resume forthwith. See note 30, ante. We reserve the question whether we have jurisdiction under the collateral order doctrine and hold this putative appeal in abeyance pending further notice from the parties, provided in writing to the Clerk of this Court.