As to claims under the Securities Exchange Act, the Act's legislative history, under which the House of Representatives version was adopted, indicates that "respondeat superior" is not applicable, because liability is only allowed if there was participation in the employee's fraud. Furthermore, courts such as the Southern District of New York have held that "respondeat superior" liability is not available under Section 10(b) of the Securities Exchange Act. Similarly, Thomas Hazen writes in "Treatise on the Law of Securities Regulation" (2005) that ""Respondeat superior" ... do[es not apply to sanctions for illegal trading on inside information."