Karonis v. Visible Spectrum, Inc.

Plaintiff filed action to recover compensation allegedly owed him by Defendants as their sports applications manager. Plaintiffs was hired for sole compensation as stock options in Defendant company. Court properly dismissed with prejudice two counts of Complaint alleging violations of Section 12(G) of Illinois Securities Law, which prohibits a person from improperly obtaining "money or property" through sale of securities. Plaintiff's services as an employee were not "money or property" under plain, ordinary, and popularly understood meanings of the terms. Plaintiff has no recourse under Section 13(A) of Illinois Securities Law, as the exchange of his services for stock options is not a "sale" under the Act. (HUTCHINSON and BIRKETT, concurring.)