Federal legislation is presumed to apply only within the territorial jurisdiction of the United States unless Congress affirmatively and unmistakably instructs otherwise.  Absent such an instruction, the court must determine the focus of congressional concern underlying the legislation and then determine whether the conduct relevant to that focus occurred in the US or elsewhere.  Here, the focus of the Lanham Act is the use of a trademark in commerce, not consumer confusion–although use of the trademark in commerce must threaten consumer confusion in order to be prohibited.  Hence, to fall within the Lanham Act’s scope, the offending use of the trademark must occur within the US.