| http://www.w3.org/ns/prov#value | - In approving this standard, we rely on decisions in other courts that have required a showing of "substantial causal connection between the culpable conduct of the alleged aider and abettor and the harm to the plaintiff[,] Mendelsohn v. Capital Underwriters, Inc., 490 F.Supp. 1069, 1084 (N.D.Cal.1979), or a showing that the encouragement or assistance is a substantial factor in causing the resul
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