In the Steele et al. v. Bulova Watch Co., Inc case of 1952, the U.S Supreme Court ruled in favor of Bulova Watch Company, affirming that American courts have jurisdiction over trademark infringement cases involving actions taken by an American citizen abroad. The defendant, Albert H. Steele was a US citizen who had been selling counterfeit watches bearing the "Bulova" name in Mexico and then importing them into Texas for sale. Despite these activities occurring outside of America's geographical boundaries, because Steele was a US citizen and his actions were causing harm to an American company within its domestic market, it fell under United States jurisdiction according to Justice Clark’s majority opinion on behalf of the court.

In the dissenting opinion for Steele et al. v. Bulova Watch Co., Inc., Justice Jackson disagreed with the majority's decision to extend U.S. trademark law into Mexico, arguing that it was an overreach of American jurisdiction and a violation of international comity principles. He contended that such extraterritorial application could lead to conflicts with foreign nations and potentially harm U.S.-Mexico relations by imposing American laws on Mexican citizens within their own country without their consent or any reciprocal arrangement in place between the two countries. Furthermore, he expressed concern about potential retaliation from other nations if they perceived this as an attempt by America to impose its legal system globally.