In Re South African Apartheid Litigation
This opinion addresses two class actions brought by South Africans against multinational corporations under the Alien Tort Claims Act (ATCA), alleging aiding and abetting torts related to the apartheid system. Specifically, the Court considered Fujitsu Limited's motion to dismiss claims against it. Plaintiffs contended that Fujitsu's subsidiary, International Computers Limited (ICL), supplied computer systems used by the apartheid-era South African government to enforce racial pass laws. The Court found that while ICL had a relationship with the South African government that predated its deep relationship with Fujitsu, the plaintiffs failed to present plausible allegations of a principal-agent relationship between Fujitsu and ICL during the relevant period of ICL's alleged unlawful activities (1981-1986). The decision to grant Fujitsu's motion to dismiss was based on the lack of sufficient evidence demonstrating Fujitsu's direct control over ICL's specific business activities concerning South Africa's pass laws, distinguishing it from other cases where vicarious liability was established.