The Colorado Court of Appeals affirmed the lower court judgment finding Master Industries Distributorships to be securities under Colorado State law. The company produced motivational courses that were sold through an MLM structure that stressed the sale of distributorships to downline member more than the sale of actual motivational courses. The Colorado Court adopted the federal standard of an investment contract from Glenn W. Turner and Koscot, an investment of money in a common enterprise, with profits to come substantially from the efforts of others.

Full case and case summary also available online at: http://www.mlmlegal.com/legal-cases/Sauer_v_Hayes.php