Howey kept half of the groves for its own use and sold real estate contracts for the other half to finance its future developments. Howey would sell the land for a uniform price per acre (or per fraction of an acre for smaller parcels) and convey to the purchaser a warranty deed upon payment in full of the purchase price.
Howey used a strategy where it kept some groves for its own use, while selling the other half to finance future developments.  For each sale, Howey would sell land at a uniform price per acre (or fraction of an acre for smaller parcels) and issue a warranty deed upon full payment of the purchase price.