First used on Jon Stewart's The Daily Show, this expression was created as an ironic play on America's near-hypocritical response to the Russian invasion of Georgia: "We cannot tolerate invasions of sovereign countries...in Europe."
Stewart compared it the the popular "...in bed" modifier for fortune cookies, in which the words "...in Europe" can be added on to any statement to create a sarcastic overtone.
"i totally pwned him in halo!" "yeah, in europe."
"Steve Guttenburg could beat Chuck Norris any day of the week...in Europe."