Federal statutes are presumed to apply only domestically–within the US’s territorial jurisdiction. The presumption is applied in a two-step framework. First, the court asks if Congress has affirmatively and unmistakably instructed that the provision at issue should apply to foreign conduct. Second, if Congress has not done so, the court asks whether the suit seeks to apply the statute domestically or to foreign conduct. Here, plaintiff sued under the whistleblower protection sections of Sarbanes-Oxley and Dodd-Frank. (15 U.S.C. § 78u-6(h)(1)(A).; 18 U.S.C. § 1514A(a). Nothing in those statutes indicated any intent to have the statutes apply to foreign conduct–while other provisions of those acts did expressly apply to foreign conduct. At step two, the court considers primarily the conduct and parties that are the focus of the pertinent statute’s concern. For both whistleblower statutes, the focus of concern was the employment relationship, the employer and the employee. Here, plaintiff, a Canadian, was hired by a Canadian company to conduct work remotely from his home in Canada. Hence, he sought impermissible foreign application of the whistleblower protection statutes even though his employment had some domestic connections.