doctrine applies at all in the context of the dormant Foreign Commerce Clause. The Supreme Court has never breached this frontier, although it has insinuated that the doctrine, if viable to any extent in the area of foreign commerce, would have to be more narrowly configured. See Reeves, 447 U.S. at 437 n. 9, 100 S.Ct. 2271 (“We have no occasion to explore the limits imposed on state proprietary actions by the ‘foreign commerce’ Clause.... We note, however, that Commerce Clause scrutiny may well be more rigorous when a restraint on foreign commerce is alleged.”). The issue has arisen sporadically in other courts, and what little case law there is appears to be in some disarray. Compare, e.g., Bethlehem Steel Corp. v. Bd. of Comm’rs, 276 Cal.App.2d 221, 228-29, 80 Cal.Rptr. 800 (1969) (<HOLDING>), with, e.g., Trojan Techs., Inc. v.
holding pennsylvania foreign attachment procedures unconstitutional holding that a ceremonial marriage performed under the laws of a foreign power by a foreign consular officer on united states territory was invalid because it did not comply with the laws of new york state holding market participant exception applicable to foreign commerce clause so as to shield state buy american law holding state buy american statute unconstitutional because it interfered with federal foreign affairs power emphasizing its effect on foreign commerce holding that the title of the statute engaging in illicit sexual conduct in foreign places and the requirement that the defendant travel in foreign commerce evinced congressional intent to apply the statute extraterritorially