On May 22, 2020, the United States Court of Appeals for the Ninth Circuit issued its opinion in Cooper v. Tokyo Electric Power Co. (TEPCO), upholding the district court’s decision to dismiss the claims against GE and TEPCO. The case was “brought in California by United States servicemembers … [who] alleg[e] they were exposed to radiation from the Fukushima Daiichi Nuclear Power Plant” when responding to the disaster. In reviewing the district court’s decision, the Court of Appeals evaluated whether a choice of law analysis between Japanese and California law was appropriate in this situation. Having concluded that it was, it affirmed the district court’s decision that the analysis favored Japan; whereas California’s interest is “in ensuring compensation for its injured residents,” Japan’s is “in the consistent application of the Compensation Act to protect its nuclear industry,” and therefore stronger, so should be applied when considering the claims against both GE and TEPCO. Based on this conclusion, the Court affirmed the district court’s decision “that Japanese law governed with respect to third-party liability and, under that law, GE could not be held liable.” Regarding TEPCO, it then evaluated “whether, given that Japanese law must be applied … the district court abused its discretion in dismissing the case on international-comity grounds.” The Court decided that the district court was justified in its decision, because it had reevaluated its prior decision based on new information, specifically the choice of law analysis and amicus briefs from Japan and the United States.