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Corporate Law—Primary-Violator Liability Under 10(b) Applies to Outside Business Partners in Suits Brought by Shareholders—Simpson v. AOL Time Warner, Inc., 452 F.3d 1040 (9th Cir. 2006)

Section 10(b) of the Securities Exchange Act of 1934 makes it illegal for a person “to use or employ, in connection with the purchase or sale of any security . . . any manipulative or deceptive device . . . .”  In 1994, the Supreme Court held that a secondary party is...