Both branches of extraterritorial criminal jurisdiction have counterparts in civil personal jurisdiction and choice of law analysis. The nationality branch of extraterritorial criminal jurisdiction corresponds to extending personal jurisdiction in a civil case over one who is domiciled in the forum state. The effects test corresponds to minimum contacts analysis in civil personal jurisdiction, especially insofar as it authorizes the assertion of personal jurisdiction in a civil case over one who acts outside the jurisdiction intending that contact with the jurisdiction will result from that person’s conduct…In general, there is no constitutional bar to the extraterritorial application of U.S. penal law. Extraterritoriality is determined by looking to congressional intent, presuming that Congress does not want to violate international law. Thus, unless Congress explicitly directs otherwise, extraterritoriality is valid to the extent permitted by international law. Additionally, choice of law does not arise in criminal cases in the same way that it arises in civil cases. The basic reason for this is that crimes were not traditionally considered transitory and thus a court either had jurisdiction or it did not. When a court had jurisdiction, it applied its own law, but a wide range of extraterritorial conduct might still be criminal. Therefore, one could be criminally liable in state A for computer-triggered conduct in state B that caused injury in state A as long as state A expressly prohibited extraterritorial conduct of that character and the actor knew or should have known of the adverse effect in state A.⁸⁹