February 24, 2026|Franchise Frontlines
February 24, 2026 | United States District Court for the Southern District of New York | Unpublished Opinion
Executive Summary
In an unpublished decision, Judge Jesse M. Furman of the Southern District of New York addressed novel claims brought by migrant construction workers under the Trafficking Victims Protection Reauthorization Act (“TVPRA”) arising from labor conditions associated with infrastructure projects built for the 2022 FIFA World Cup in Qatar. Rather than suing the construction companies that directly employed them, the plaintiffs asserted claims against several U.S.-based public relations and lobbying firms that provided communications and reputation-management services to Qatari government entities involved in the World Cup. The defendants moved to dismiss on multiple grounds, including lack of jurisdiction, extraterritorial limits of the statute, and failure to state a claim. The court rejected many of the defendants’ arguments and held that plaintiffs plausibly alleged that certain firms knowingly benefited from participation in a venture that engaged in forced labor, allowing those claims to proceed. The court dismissed claims against some defendants and limited the scope of the surviving TVPRA claims.
Relevant Background
The plaintiffs are more than one hundred migrant construction workers who alleged that they were trafficked to Qatar and forced to work under abusive conditions while constructing stadiums and infrastructure related to the 2022 FIFA World Cup. According to the complaint, the workers were recruited with promises of lawful employment but, upon arrival in Qatar, were subjected to practices that included passport confiscation, excessive working hours, unsafe working conditions, and delayed or withheld wages.
Instead of suing their direct employers in Qatar, the plaintiffs brought claims in U.S. federal court against several public relations and lobbying firms. The complaint alleged that these firms were retained by Qatari government entities and organizations associated with the World Cup to monitor media coverage, develop communications strategies, respond to criticism, and influence international perceptions of Qatar’s labor practices.
The plaintiffs alleged that these services formed part of what they described as the “World Cup Labor Venture,” a coordinated effort involving Qatari government entities, construction employers, and communications firms aimed at ensuring that stadiums and related infrastructure could be built on schedule despite international criticism of labor conditions.
The defendants moved to dismiss the case, arguing that the plaintiffs lacked standing, that the court lacked personal jurisdiction over certain defendants, and that the complaint failed to state claims under the TVPRA. They also argued that the claims were barred by the statute’s extraterritorial limits, the act-of-state doctrine, and the First Amendment.
Decision
The court issued a detailed decision granting the motion to dismiss in part and denying it in part.
First, the court held that the plaintiffs had Article III standing to pursue their claims. The defendants argued that the plaintiffs’ injuries were not fairly traceable to the public relations firms because the firms did not directly employ or supervise the workers. The court rejected that argument at the pleading stage, explaining that the TVPRA allows civil claims against entities that knowingly benefit from participation in a venture that engages in forced labor. The court concluded that the complaint plausibly alleged that the defendants’ communications and lobbying efforts were intended to shield labor abuses from international scrutiny and thereby support the broader venture.
Second, the court addressed whether the complaint plausibly alleged that the defendants “participated in a venture” within the meaning of the TVPRA. The court explained that participation requires more than an ordinary commercial relationship but may be established when a defendant provides active and ongoing support tailored to advance the venture’s objectives. Applying that standard, the court held that the allegations against several public relations firms were sufficient to plausibly show participation because the complaint described extensive work aimed at countering media reports, managing public messaging, and assisting Qatari entities in responding to criticism of labor practices.
However, the court dismissed the claims against the corporate parent company of one of the public relations firms because the complaint did not plausibly allege that the parent itself participated in the venture beyond providing routine corporate services.
The court also examined the TVPRA’s knowledge requirement and held that the plaintiffs plausibly alleged constructive knowledge. The complaint described widespread reporting by governments, international organizations, and media outlets documenting labor abuses connected to World Cup construction. Because the defendants were allegedly hired to monitor and respond to that reporting, the court concluded that it was plausible they knew or should have known of the underlying labor practices.
The court then addressed the statute’s extraterritorial limits. It concluded that the TVPRA may apply extraterritorially when the predicate criminal provisions authorize such application. But the court determined that certain claims still failed because the alleged trafficking conduct occurred abroad and did not satisfy the statute’s specific requirements for extraterritorial jurisdiction as applied to some defendants.
Finally, the court rejected several other defenses. The court concluded that the act-of-state doctrine did not bar the claims because the case did not require the court to invalidate any official act of the Qatari government. The court also rejected the defendants’ First Amendment defense, explaining that speech used as part of unlawful conduct—such as knowingly assisting a venture engaged in forced labor—may fall outside First Amendment protection.
Looking Forward
This decision illustrates how courts are interpreting the scope of civil liability under the TVPRA, particularly in cases involving complex multi-actor ventures rather than direct employer–employee relationships.
The court’s analysis of “participation in a venture” emphasizes that liability may arise when entities provide active, targeted support that advances a venture engaged in trafficking or forced labor, even if those entities are not directly involved in the underlying labor practices. At the same time, the decision underscores that courts continue to scrutinize whether allegations demonstrate meaningful participation rather than routine commercial relationships.
For businesses operating in complex international environments, the ruling highlights the importance of carefully evaluating the nature of services provided to counterparties engaged in high-risk activities or industries. Courts increasingly examine the broader operational context of commercial relationships when assessing whether a defendant knowingly benefited from participation in a venture that allegedly violated the TVPRA.
The decision also provides a detailed discussion of the statute’s extraterritorial limits, emphasizing that the reach of the TVPRA’s civil remedy depends on the scope of the underlying criminal provisions. As litigation under the statute continues to expand into new factual contexts, courts are likely to continue refining how these jurisdictional boundaries apply in practice.
This article is based solely on the opinion of the Court in this matter. The author has not conducted any independent investigation into the facts. For the avoidance of doubt, each statement related to the law and facts in this article is drawn from the Court’s opinion in this case.
Thomas O’Connell is a Shareholder at Buchalter LLP and Chair of the firm’s Franchise Practice Group. For questions about this article or media inquiries, you can contact Tom at toconnell@buchalter.com.
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