Case analysis
An unsuccessful attempt to profit can still matter in a forced-labor case
The Ninth Circuit’s 2026 Ratha decision connects a seafood supply chain, a congressional amendment and the reopening of a judgment.
Decision:
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Industry & Economics
Examine business relationships and the economics of exploitation through decisions and published research.
Begin hereThe economics of forced labour →
9 resources
Original explainer
Trafficking has an economy. Its statistics do not all measure the same thing.
Profit estimates, detected victims and suspicious transactions answer different questions. Keeping the units straight makes the business model clearer.
Case source
G.G. v. Salesforce.com, Inc.
The Seventh Circuit revived a civil claim based on alleged tailored business support for Backpage and rejected dismissal under Section 230 for the claim as pleaded.
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Case source
Doe 1 v. Apple Inc.
The D.C. Circuit held that the pleaded cobalt-purchasing relationships did not establish venture participation. It affirmed dismissal for failure to state a claim.
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Research source
The economics of forced labour
The ILO estimates global private-economy forced-labour profits. Its $236 billion figure uses 2021 inputs and is not a U.S. trafficking revenue total.
Report publication date:
article
A hotel trafficking judgment faces a challenge over knowledge and proof
An Arizona hotel trafficking judgment faces a pending reconsideration request. Read what the order decided, what the plaintiff contests and how Northbrook differs.
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article
A supply chain is not, by itself, a venture.
The D.C. Circuit’s Apple cobalt-supply-chain decision: standing, ordinary purchasing, and the limits of beneficiary liability under the TVPRA.
article
Beyond a room rental: what can reach a jury?
A guide to the Eleventh Circuit’s 2026 Northbrook and Naseeb decision on hotel trafficking claims at summary judgment.
article
When business support becomes the alleged connection
Understand the 2023 Salesforce pleading decision, its limits, and the later civil stay, with public court sources and source references.