This Article first provides an overview of the Section 14(a) of the Securities Exchange Act of 1934 private right of action. Thereafter, the Article explores the implication of rights of action generally under federal law as well as the development of the implied right, its elements, and scope...

In a decision that delighted "deep pockets," shocked the plaintiffs' bar, and befuddled neutral observers, the Supreme Court in Central Bank of Denver v. First Interstate Bank of Denver held that aiding and abetting liability in private actions may not be imposed under section 10 (b) of the...