In Part I of this Article, we provide a description of the facts and holding of United States v. Bowman. In Part II, we describe the ways in which lower courts have interpreted this decision. We point to various cases citing Bowman and show how these courts give exceedingly broad application to the holding - far broader application than the opinion warrants. Finally, in Part III, we discuss the ways in which the courts should read Bowman and demonstrate how this more accurate reading of the Court\u27s decision is consistent with the realities of twenty-first century global economies. In doing so, we illustrate how Bowman can be a leading case for a sensible international criminal jurisdiction jurisprudence in a global age