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Did James Joyce Inspire Howey?

Anyone who has studied securities regulation has been exposed to the United States Supreme Court's decision in SEC v. W.J. Howey, 328 U.S. 293 (1946) establishing the definition of  "investment contract" under the Securities Act of 1933.  The transactions at issue in that case involved the sale of citrus land and service agreements in Lake County, Florida.

Apparently, the idea of selling citrus investments was far from a novel idea.  James Joyce even describes such a scheme in his "Calypso" chapter of Ulysses:

He [Leopold Bloom] walked back along Dorset street, reading gravely.  Agendath Netaim [Plantations Association in Hebrew]: planter's company.  To purchase vast sandy tracts from Turkish government and plant with eucalyptus trees.  Excellent for shade, full and construction. Orangegroves [sic] and immense melonfields [sic] north of Jaffa.  You pay eight marks and they plant a dunam [approximately 900 square meters] of land for you with olives, oranges, almonds or citrons.  Olives Cheaper: oranges need artificial irrigation.  Every year you get a sending of the crop.

For more on Leopold Bloom, see this post.

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Securities Act of 1933

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