to the detriment of both investors and the market as a whole.” Id. Accordingly, we have no warrant for overturning the SEC’s determination that Broumas violated section 10(b) and Rule 10b-5. B Having concluded that Broumas’ stock-kiting scheme constituted a primary-violation of the securities laws, the next question is whether Graham substantially assisted Broumas in that violation. We have no doubt that she did. Graham placed 60 directed trades for Broumas, an average of one every week-and-a-half during the 18-month period at issue. She opened the Les Girls account and executed wash trades from both that account and from the account of Lawton Rogers. Such conduct is more than sufficient to constitute substantial assistance. See SEC v. U.S. Envtl., Inc., 155 F.3d 107, 112 (2d Cir.1998) (<HOLDING>). Graham contends that this conclusion is
holding trader who recklessly executed manipulative buy and sell orders for customer liable as primary violator holding that arbitration clause which was included with product mailed to customer and with proviso that customer could return product within 30 days was binding on customer who did not return computer holding that an independent engineering company that played a significant role in developing allegedly false statements made by a mineral exploration company could be held liable as a primary violator holding corporation vicariously liable for assault on customer by assistant manager as customer was engaged in trying to settle a controversy concerning a portion of defendants business holding that murder committed by customer was not foreseeable result of excessive sale of alcohol to customer