S.Ct. 1439. The Courts of Appeal have disagreed on how to apply Central Bank to determining when independent auditors have primary liability. One standard, espoused by the 9th Circuit in In re Software Toolworks, Inc., 50 F.3d 615, 628 (9th Cir.1994), holds that an accountant that “play[s] a significant role in drafting and editing” a materially false and misleading statement may be held primarily hable under § 10(b). In that case, the accountant allegedly “improperly computed] the financial statements” included in a software company’s prospectus, “assist[ed]” the company in drafting misleading letters to the SEC, and “enabl[edj” the company to issue false financial statements for the June quarter. Id. at 627. See also In re ZZZZ Best Sec. Litig., 864 F.Supp. 960, 970 (C.D.Cal.1994) (<HOLDING>). Some district courts in other circuits have
holding auditor liable for reviewing public statements holding that the creation drafting editing or making of the statements at issue can give rise to liability under  10b holding that evidence was intricately related because it explained the circumstances surrounding the relationships of the people involved in the conspiracy holding an auditors review and approval of quarterly financial statements nonactionable under  10b and stating that because defendant did not actually engage in the reporting of the financial statements  but merely reviewed and approved them the statements are not attributable to defendant and thus defendant cannot be found liable for making a material misstatement holding that an auditor intricately involved in the creation of misstatements and omissions may be liable under  10b even if the statements could not be reasonably attributable to him