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OCR: rcquired to have engaged in manipulative of deceptive conduct, nut merely to have substantially assisted such Each of the courts appeals which har the issue considers "substan tial assistance" of primary violalion 0 10(b) ar element aiding and abetting liability, although there little unilormity the courts application of the "subsi lantial assistance standard. Because substantial assistance of violation not the conduct prohibited by the statute, courts are entirely without guit- ance who may be subj jected to liability.13 refusing extend H1 implied private action alleged aiders and abettors 10{b) violations the Court can eliminate the tual quagmire of the suhstantial assistance 15a1 while honoring the Congressional intent to require manipulative or deceptive conduct the defendan in Implied ...