was encountering in the fall of 1995, defendants pursued a “conspiracy of silence” to prevent any negative information from reaching the marketplace. Plaintiffs contend that, through this conspiracy, defendants propped up SGI stock prices long enough to enable defendants to sell off their shares at high prices. Plaintiffs accuse defendants of affirmatively misleading the public by false and misleading statements and of violating the abstain or disclose doctrine prohibiting insider trading. Although plaintiffs need not allege that every defendant participated in every aspect of a fraudulent scheme to state a claim, section 10 liability requires a finding that each individual took some action in furtherance of the scheme. See Azrielli v. Cohen Law Offices, 21 F.3d 512, 517 (2d Cir.1994) (<HOLDING>). The cases cited by plaintiffs support this
holding that joint and several liability for entire actual loss could have been imposed on each fraud defendant as condition of probation holding that primary liability may be imposed only on those committing a fraud or assisting in its perpetration holding that whatever direct corporate liability nordstrom had for fraud would be concurrent with director and officer liability since the directors and officers were liable for authorizing the fraud holding that reversal for a new trial on liability is appropriate only where the error complained of affects only the issues of liability holding that a plaintiff cannot avoid the securities fraud exception by pleading mail fraud or wire fraud if the conduct giving rise to those offenses also amounts to securities fraud