...offers or sella for an Issuer In connection with, the distribution of any security, or participâtes or has a direct or Indirect participation In any such...participation in the direct or Indirect underwriting of any snob, undertaking. The Interpretation of thla definition has traditionally focused on the words "with...

...An "underwriter" is defined by Section 2 (11) of the Securities Act of 1933 as "any person who . . . sells for an issuer in connection with, the distribution...or indirect participation in any such undertaking ..." It is clear that the sales by Outlook Investments, Ltd., of stock loaned to it by the officers,...

...a large stockholder who subscribes to new shares and then sells could be defined as an underwriter: "any person who has purchased from an issuer with...connection with the distribution of any security. . . ."17 Since the company is instructed to report to the SEC the names and addresses of the principal...

...executed. (11) The term " underwriter " means any person who has purchased from an issuer with a view to, or sells for an issuer in connection with, the distribution...participates or has a participation in the direct or indirect underwriting1 of any such undertaking ; but such term shall not include a person 'whose interest is...

...statement until the objections on ichich such order is based have been met." SEC LEGISLATION I (4) The term "underwriter" means any person who has purchased...an issuer in connection with, the distribution of an; security, or participates or has a direct or indirect participation in any such undertaking, or...

...evidence amply supports the hearing examiner's con* Section 2(11) defines an "underwriter" in part as "Any person who has purchased from an issuer with...or indirect participation in any such undertaking." For purposes of Section 2(11), the term "issuer" is denned to include "any person directly or indirectly...

...executed. " (4) The term 'underwriter' means any person who has purchased from an issuer with a view to, or sells for an issuer in connection with, the distribution...participation in any such undertaking, or participates or haa a participation in the direct or indirect underwriting of any such undertakng; but such term shall...

...seller is an "underwriter." The term underwriter is broadly defined in Section 2(11) of the Act to mean any person who has purchased from an issuer with a...or indirect underwriting of any such undertaking. The interpretation of this definition has traditionally focused on the words "with a view to" in the...

...company. ******* (20) "Underwriter" means any person who has purchased from an issuer with a view to, or sells for an issuer in connection with, the distribution...participates or has a direct or indirect participation in any sucn undertaking, or participates or has a participation in the direct or indirect underwriting of...

...purposes of Section 4(l) generally is on tne term "underwriter." Section 2(ll) defines an underwriter as "any person who has purchased from an issuer with...indirect participation in any such undertaking..." In addition, the last sentence of Section 2(ll) provides that the term "issuer", as used in the section,...