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OCR: posed congressional intent t0 erase other forms of com- mon law secondary liability Petitioner also maintains that no right of action for aiding and abetting need be recognized because Congress 'decided" not enact ainendments proposed r 1957. in 1959 and 1960 that would, among other things have cluded within 20 an press aiding and abotting Icmedy for SEC injunctive actions. Brief PP 20-22 However. as this Court has stated + perhaps understated, unsuc- cessful attempts legislation are not the best guides tri legislative intent Rea ion Broadcasting The First Secand, Fourth, Fifth, Sixth, Seventh, Eighth, Ninth and Tenth Circuita have held that controlling person liability i8 intended to supplement, not supplant existing forms of sccand- ar Hability. See, Atlantic Fin Managetent, Inc. AZI Seo ...