NSF lease transaction rendered him a ‘real estate salesperson’ in Virginia,” and therefore required him to be licensed as such. Appel-lee’s Br. at 17. 2 . The Supreme Court of Virginia first addressed the issue of commission payments to unlicensed brokers and salespersons in Massie v. Dudley, refusing to enforce an agreement "made by an unlicensed person” because "its substance [was] unlawful.” 173 Va. 42, 3 S.E.2d 176, 180-81 (1939). The court has consistently reiterated this principle following Massie. In Harrison & Bates, Inc. v. LSR Corp., for example, the court held unenforceable a contract to split commissions made between a licensed corporation and an unlicensed firm. 238 Va. 741, 385 S.E.2d 624 (1989); see also Hancock, Co. v. Stephens, 177 Va. 349, 14 S.E.2d 332, 334 (1941) (<HOLDING>); State Realty Co. v. Wood, 190 Va. 321, 57
holding that a contract to sell real property was unenforceable because it did not contain a sufficient description of land subject to contract holding unenforceable a contract for real estate commissions formed by an unlicensed corporation holding unenforceable a real estate contract that provided for the payment of brokerage fees to an unlicensed corporation holding that an appeal became moot when the party sold the real estate that formed the basis of the claims holding prospectively that a vendees interest in a real estate contract constitutes real estate within the meaning of the judgment lien statute