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14 “affirmative act” “with the intent of facilitating the offense’s commission.” Rosemond, 572 U. S., at 71. Such intentional participation can come in many forms, including abetting, inducing, encouraging, soliciting, or advising the commission of the offense, such as through words of encouragement or driving the getaway car. 2 LaFave §13.2(a), at 457–460; see also J. Hawley & M. McGregor, The Criminal Law 81 (3d ed. 1899). Regardless of the particulars, however, it is clear that some culpable conduct is needed. See Rosemond, 572 U. S., at 73, 77.

Similar principles and concerns have shaped aiding-and-abetting doctrine in tort law, with numerous cases directly employing them to help articulate the standard for tortious aiding and abetting. See, e.g., Zoelsch v. Arthur Andersen & Co., 824 F. 2d 27, 35–36 (CADC 1987); Woodward, 522 F. 2d, at 95, n. 23; Landy, 486 F. 2d, at 163–164 (all relying on Nye & Nissen, 336 U. S., at 619); see also Camp v. Dema, 948 F. 2d 455, 459 (CA8 1991) (relying on People v. Terman, 4 Cal. App. 2d 345, 346–347 (1935), another criminal case). Similar to the criminal-law rule, some cases have required that the defendant’s assistance “must have had a direct relation to the trespass, and have been calculated and intended to produce it” to warrant liability for the resulting tort. Bird, 49 Ky., at 423; see also Smith v. Thompson, 103 Idaho 909, 911, 655 P. 2d 116, 118 (App. 1982); Brown, 83 Mass., at 98. Other cases have emphasized the need for some “culpable conduct” and “some degree of knowledge that [a defendant’s] actions are aiding the primary violator” before holding the defendant secondarily liable. Camp, 948 F. 2d, at 460. Still others have explained that “[c]ulpability