In U.S. securities law cases in which "respondeat superior" has been considered, where the company was not a knowing participant in the employee's fraud, the results have been mixed. In "O'Brien v. Dean Witter Reynolds" (D. Ariz 1984), the court, emphasizing the requirement of knowing participation, stated that an employee's knowledge could not be imputed to the employer. The court in "Dakis v. Chapman" (D. Cal. 1983) stressed the concept of intentional participation; liability would not attach to a firm that was merely a "conduit" for the employee's securities violations. In "Parnes v. Heinold Commodities" (N.D. Ill. 1983), the court described the use of "respondeat superior" as "bizarre", noting that the firm itself had been victimized by its unscrupulous employee.