532 (1992) (interpreting the “by reason of’ language in the civil RICO statute as incorporating common-law principles of proximate causation)). In light of our recent decision in Rothstein, 708 F.3d at 82, we find the Rule 12(b)(6) defendants’ arguments persuasive. First, Rothstein specifically held that a defendant cannot be liable under the ATA on an aiding-and-abetting theory of liability. Id. at 97 (“[W]e are not persuaded that the district court erred in concluding that plaintiffs had not stated a claim on which relief could be granted against UBS on an aiding-and-abetting theory, because it does not appear to us that Congress intended § 2333(a) to permit recovery on such a.theory.”); see also Boim v. Holy Land Found for Relief & Dev., 549 F.3d 685, 689 (7th Cir.2008) (en banc) (<HOLDING>); cf. Cent. Bank of Denver, N.A., 511 U.S. at
holding that massachusetts statute did not create a sufficiently close nexus between private hospital and the state to warrant labeling private actors state actors holding that foster parents are not state actors holding private actors are not acting under the color of state law for the purposes of section 1983 liability holding that statutory silence on the subject of secondary liability means there is none and section 2333a  does not mention aiders and abettors or other secondary actors holding that wlhether any particular cause or any individual actors conduct is sufficiently substantial to warrant the imposition of liability depends properly on a consideration of the whole