territorial waters. See Howard, 41 F.3d at 530 (noting that “the law in question was expressly designed to cover wrongful deaths occurring outside the territorial boundaries of the United States.”). Finally, we consider the effect of the Director’s support for Tracy’s interpretation. We deem reasonable interpretations of the Director to have “at least some” persuasive force if the statute is silent or ambiguous with respect to the specific issue and the Director’s interpretation is based on a permissible construction of the statute. Metro. Stevedore Co. v. Rambo, 521 U.S. 121, 136, 117 S.Ct. 1953, 138 L.Ed.2d 327 (1997); see also Skidmore v. Swift & Co., 323 U.S. 134, 140, 65 S.Ct. 161, 89 L.Ed. 124 (1944); Price v. Stevedoring Servs. of Am., 697 F.3d 820, 832 (9th Cir.2012) (en banc) (<HOLDING>). According to the Director, “[i]n the absence
holding regulations entitled to chevron deference holding in the chevron context that deference to what appears to be nothing more than an agencys convenient litigating position would be entirely inappropriate holding that a longstanding agency interpretation was no longer entitled to chevron deference given that the agency had changed its position on the issue holding that the directors litigating position was not entitled to chevron deference but did warrant skidmore respect on certain issues where the arguments were persuasive and the agencys manual and practice had for some time consistently advanced a reasonable position holding that courts will not defer to an agencys litigating position where it contradicts the agencys prior regulations rulings or administrative practice