Commodity pool investors were defrauded by their pool operator, who traded the pooled funds for his own account through futures commission merchants. The investors sued the merchants under the Commodity Exchange Act (CEA) for aiding and abetting the pool operator's scheme. On September 16th, the Fifth Circuit affirmed dismissal of the complaint for failure to state a claim, holding that the investors had not sufficiently alleged that the merchants had "willfully" aided and abetted the CEA violations. The court considered, but did not have to decide, whether "willfully" aiding and abetting requires actual knowledge and specific intent to further the violations or, instead, may require only "extreme recklessness" when there is a special duty of disclosure or when the assistance provided is unusual in character or degree, because the investors' allegations in this case did not meet either standard. Amacker v. Renaissance Asset Management LLC.