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OCR: common law See United States Martin. 176 F. 110. 113-14 (N.D Iowa 1910) Petitioner maintains that the 1934 Congress may be seen to hayc excluded other forms of secondary liability such as aiding pur abetting simply because enacted controlling person liability under 20 of the 1934 Act (which applies dircctly to civil liability under 10b) and undcr of the 1933 ct (1988 The legislative history this spcculation. Congress enacted of the 1933 put of the 1934 Act provide novel mechanism 0f secondary liability. not present the common law and especially suited ts the securities markctplace. where parties who would otherwise be culpable might escape accountability by operating from behind the scencs There no per suasive basis to extrapolate from these provisions sup Noihing in the legislative histor ...