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How did Justice Marshalls ruling in Herman & MacLean v. Huddleston enhance the usefulness of Section 10(b) and 10(b)-5 to protect investors from securities fraud?

How did Justice Marshalls ruling in Herman & MacLean v. Huddleston enhance the usefulness of Section 10(b) and 10(b)-5 to protect investors from securities fraud? How might these enhanced protections affect the potential liability of auditors for misstated stated financial statements?

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