Corporate Lobbyists Abroad: The Extraterritorial Application of Neorr-Pennington Antitrust Immunity

The magnitude of direct investment by United States corporations in the world economy is staggering. For example, the gross annual product of American foreign investment is exceeded only by the gross national products of the United States and Russia.' This corporate activity has a tremendous impact on the economy of the United States;2 it is not surprising, therefore, that much of it has been brought within the scope of United States antitrust laws.8 The problem of defining the exact limits of the applicability of these laws to foreign investment activity, however, has long plagued courts and commentators.4 This Comment considers one facet of that problem: whether the Noerr-Pennington doctrine, which provides that corporations do not violate the antitrust laws when they lobby on the state or federal level for the enactment of anticompetitive legislation,5 should be ex-