id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
cblr-14241	Graves, Noah	Controlling the Controllers: Section 20(a) Control Person Liability and Promoting Gatekeeper Behavior Among Officers and Directors: Noah Graves	2025	38	.pdf	application/pdf	12792	555	51	[Vol. 2024 point of agreement is that there must be a breach of federal securities law before control person liability can be considered.10 Courts have rejected Section 20(a) claims that lack a sufficient allegation of a predicate breach of relevant federal securities laws.11 Second, the individual or entity being sued under Section 20(a) must be a controlling person, having some degree of control or authority over the violator.12 Finally, multiple circuits agree that the controlling person has the opportunity to establish the affirmative defense of good faith based on the statutory language of Section 20(a).13 Thus, control person liability under Section 20(a) cannot survive.”).	cache/cblr-14241.pdf	txt/cblr-14241.txt