The District court held that Koscot was not a security under the law of the circuit. The court felt compelled to follow earlier circuit precedent in deciding that profits must come "solely" from the efforts of others for an investment program to be considered a security. While other circuits had adopted a more flexible functional security test, the Eleventh Circuit had not, and it was up to the higher courts to change the standards to be applied to programs like Koscot.
Full case and case summary also available online at: http://www.mlmlegal.com/legal-cases/SEC_v_KoscotInterplanetary365FSupp588-1973Dist-Ct.php
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