BIRCH, Circuit Judge:
This appeal arises from the district court's grant of summary judgment to Mass Media Marketing, Inc. ("Mass Media"), Commodity Referral Service, Inc. ("CRS"), and Rolando Nanasca (hereinafter collectively known as "Advertisers"), and the district court's denial of a cross-motion for partial summary judgment by Commodity Futures Trading Commission ("CFTC"). The district court held that the Introducing Broker registration and record-keeping requirements...
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