The following excerpt is from Narducci v. Neighbor, 907 F.2d 155 (9th Cir. 1990):
The elements of a cause of action for aiding and abetting under section 10(b) are: (1) the existence of an independent primary wrong; (2) actual knowledge by the aider and abettor of the wrong and of his or her role in furthering it; and (3) substantial assistance in the wrong.
Harmsen v. Smith, 693 F.2d 932, 943 (9th Cir.1982), cert. denied, 464 U.S. 822 (1983).
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