I was thinking more multinational corp, where there could be interesting questions if the US could in edge-cases still count as touching the context of the (cle

I was thinking more multinational corp, where there could be interesting questions if the US could in edge-cases still count as touching the context of the (clearly existing) EU establishment. E.g. if an employee in an EU office happened to do one interview stage or was otherwise involved, they'd have done "data processing" in the EU. Or if the same hiring process and organization also runs the equivalent for EU offices, does that pull it in through same way. Etc. Very possible that not, just not something I'd be confident on for all cases. Of course a large multinational is also likely to have had people look at these questions and design their process around them where needed. Good point on the lawsuit risk being a reason to be strict though.