Read the following excerpt from a US court opinion:
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a Section 15(d) violation based on Section 104 of the Private Securities Litigation Reform Act and the test for aiding and abettor liability for Section 10(b) violations); Graham v. SEC, 222 F.3d 994, 1000 (D.C.Cir.2000) (identifying three principal elements to establish liability for aiding and abetting a Section 10(b) and Rule 10b-5 violation as “(1) that a principal committed a primary violation; (2) that the aider and abettor provided substantial assistance to the primary violator; and (3) that the aider and abettor had the necessary ‘scienter’ .... ”); accord SEC v. Arthur Young & Co., 590 F.2d 785, 786 (9th Cir.1979) (recognizing aiding and abetting liability under Sections 10(b), 13(a) and 15(d) of the Exchange Act); SEC v. Kalvex, Inc., 425 F.Supp. 310, 316 (S.D.N.Y.1975) . The first prong of the aider and abettor test
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What is the most suitable continuation to the opinion? Your options are:
A. recognizing aiding and abetting conversion
B. recognizing aiding and abetting trespass
C. recognizing both aiding and abetting breach of fiduciary duties and aiding and abetting conversion
D. holding corporate director liable for aiding and abetting violations of exchange act sections 14a 13a and rules 13al and 13a13 because he provided assistance and encouragement to conduct patently in violation of the securities laws
E. holding it was not a surprise or unfair to the defendant for the state to pursue a theory of aiding and abetting at trial when the charging document did not refer to aiding and abetting
Reply with [A, B, C, D, E] only.