The Securities and Exchange Act of 1934 has had extensive impact on public awareness of corporate information, and has unquestionably provided substantial protection to the investing public. The anti-fraud provisions of this act, and the regulations promulgated thereunder, engendered a number of issues material to the determination of the standards for violations. Perhaps the most difficult and confusing of these issues has been the concept of scienter.
Note, Scienter and Rule 10b-5: Development of a New Standard..., 23 Clev. St. L. Rev. 493 (1974)