The Immigration and Nationality Act defines a United States national as "(A) a citizen of the United States, or (B) a person who, though not a citizen of the United States, owes a permanent allegiance to the United States." 8 U.S.C.  110 l (a)(22). The latter category has long been understood to primarily include persons born in the outlying territories of the United States; however, non-citizen national status is not limited under the INA to such persons. The broad language of the statute, the relevant case law, and the historical record all compel the conclusion that non-citizens born outside of United States territories may also acquire national status through objective manifestations of allegiance to the United States. See, e.g., Lee v. Ashcroft, 216 F. Supp. 2d 51 (E.D.N.Y. 2002) (holding that non-citizen demonstrated the requisite permanent allegiance to the United States to acquire national status by registering for selective service applying for citizenship, and by life-long immersion in American society).