In Central Bank of Denver v. First Interstate Bank of Denver, 511 U.S. 164, 181-82, 114 S.Ct. 1439, 128 L.Ed.2d 119 (1994), the Supreme Court held that although 10(b) of the Securities and Exchange Act, 15 U.S.C. 78j, did not prohibit aiding and abetting liability, "the private plaintiff may not bring a 10b-5 suit against a defendant for acts not prohibited by the text of 10(b)," 511 U.S. at 173, 114 S.Ct. 1439. The Court declined to create a presumption against aiding and abetting liability, but instructed that when Congress enacts a statute, there is no presumption in favor of aiding and abetting liability. Id. at 182, 114 S.Ct. 1439.