In Pinter v. Dahl (1988) 486 U.S. 622, the Supreme Court considered whether the "seller" requirement imposed by section 12 of the Securities Act of 1933 could be satisfied by allegations that a defendant substantially participated in a sale of securities. The court found no support in the statutory language or legislative history for expanding liability beyond the seller of the security. (Pinter v. Dahl, supra, at p. 650.) In reaching this decision, the court noted that Congress was aware of the collateral participation concept and employed it in such legislation as section 9 of the 1934 Securities Exchange Act, more specifically in 15 United States Code section 78i(e). ( Pinter v. Dahl, supra, at p. 650, fn. 26 108 S. Ct. at p. 2080.)