is different from whether they adequately plead a violation of the law of nations). Plaintiffs cite to several documents of international consensus that prohibit the modern forms of forced labor alleged in the FAC. (FAC ¶ 170.) Plaintiffs also point to numerous international conventions which prohibit human trafficking. (Id.) Numerous courts within the United States have found trafficking, forced labor, and involuntary servitude cognizable under ATS. See, e.g., Licea v. Curacao Drydock Co., Inc., 584 F.Supp.2d 1355 (S.D.Fla.2008) (finding that alleged forced labor and international human trafficking of plaintiff by operator of a drydock facility constituted violations of international law); In re World War II Era Japanese Forced Labor Litigation, 164 F.Supp.2d 1160, 1179 (N.D.Cal.2001) (<HOLDING>); Doe v. Unocal Corp., 963 F.Supp. 880, 892
holding forced stomach pumping shocks the conscience and violates substantive due process holding that state law claim regarding breach of settlement agreement was preempted by federal labor law holding that state law fraud claims are preempted by the federal labor law duty of fair representation holding that forced labor violates the law of nations holding plaintiff must charge that the alleged breach violates a contract between two labor organizations