OPINION
COMPTON, Justice.
I. FACTUAL AND PROCEDURAL BACKGROUND
This is an appeal from the superior court's affirmance of a cease and desist order entered by the Division of Securities against Caucus Distributors, Inc. (Caucus). It requires an interpretation of Alaska's "Blue Sky" laws, AS 45.55.010-.270; specifically, under what circumstances are notes within the statutory definition of covered "securities."
Caucus is self-described as...
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