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Rh and factors as a way to synthesize the common-law approach to aiding and abetting. And JASTA employs the common-law terms “aids and abets,” pointing to Halberstam’s common-law “framework” as the primary guidepost for understanding the scope of §2333(d)(2).

At bottom, both JASTA and Halberstam’s elements and factors rest on the same conceptual core that has animated aiding-and-abetting liability for centuries: that the defendant consciously and culpably “participate[d]” in a wrongful act so as to help “make it succeed.” Nye & Nissen, 336 U. S., at 619. To be sure, nuances may establish daylight between the rules for aiding and abetting in criminal and tort law; we have described the doctrines as “rough[ly] simila[r],” not identical. Central Bank of Denver, 511 U. S., at 181. But we need not resolve the extent of those differences today; it is enough for our purposes to recognize the framework that Halberstam set forth and the basis on which it rests. The phrase “aids and abets” in §2333(d)(2), as elsewhere, refers to a conscious, voluntary, and culpable participation in another’s wrongdoing.

The next question, however, is what precisely a defendant must aid and abet. As noted above, JASTA imposes liability on anyone “who aids and abets, by knowingly providing substantial assistance, or who conspires with the person who committed such an act of international terrorism.” §2333(d)(2). The parties vigorously dispute the textual object of the term “aids and abets”: Plaintiffs assert that it is “the person,” and defendants insist that it is the “act of international terrorism.” So, plaintiffs contend, defendants can be liable if they aided and abetted ISIS generally—there is no need for defendants to have aided and abetted the specific Reina nightclub attack. Conversely, defendants posit that they are liable only if they directly aided and