4331. The Rule 12(b)(6) defendants respond that: (1) the ATA does not provide for secondary liability as the statute is silent on that issue, see Al Rajhi Bank Br. 41 (citing Cent. Bank of Denver, N.A. v. First Interstate Bank of Denver, N.A., 511 U.S. 164, 182, 184, 114 S.Ct. 1439, 128 L.Ed.2d 119 (1994) (noting that “there is no general presumption that [a] plaintiff may ... sue aiders and abettors” and that statutory silence regarding aiding and abetting liability “indicates a deliberate congressional choice with which the courts should not interfere”)); and (2) plaintiffs do not allege the actions of the Rule 12(b)(6) defendants proximately caused their injuries, see id. at 29 (citing Holmes v. Sec. Investor Prot. Corp., 503 U.S. 258, 267, 112 S.Ct. 1311, 117 L.E , 114 S.Ct. 1439 (<HOLDING>). Second, we held in Rothstein that Congress
holding that the lower courts erred in finding that the question of the extraterritorial reach of  10b of the securities and exchange act of 1934 was jurisdictional even though nothing in the analysis of the courts below turned on this mistake holding that a private plaintiff is not entitled to maintain an aiding and abetting action under  10b or rule 10b  5 holding of wilko equally applicable to cases arising under the securities exchange act of 1934 holding that claims under  10b of the securities exchange act of 1934 were arbitrable under a predispute arbitration agreement holding that an implicit congressional intent to impose  aiding and abetting liability could not plausibly be inferred from the statutory silence in  10b of the securities exchange act of 1934