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Applying that " flexible " approach , the Court in Howey concluded that the investments at issue there - fee-simple interests in citrus groves packaged with service contracts to cultivate the land , sell the fruit , and remit any profit to the investors-were investment contracts . Some interviewees differentiated helpfully between two groups of customers - direct customers ( those who were in direct receipt of the Department ’ s money , advice or regulatory functions ) and end customers or beneficiaries ( those that are intended to benefit from the outcomes of schemes and services ) . Again Tannenbaum errs , in projecting Mays ' current alienated persona backward to a time when properly he was seen as affable and media - friendly as Ruth ( cf 1st national b'cast of The Tonight Show , 1954 , where he is visited in Harlem by Steve and Edie ) . " Brussels , 6 October 2000 - Direct investment , joint-ventures , support for local firms and partnerships with international financial institutions are all ways the world business community can help promote stability and economic growth in the shattered region of the Balkans . The point to be grasped is that this type of Satanist theology is shaped by any given number of magico - religious beliefs and does not arise just in reaction to Christianity . A supplemental request to Congress for $ 7 million in economic support and $ 15 million for military aid ( up from $ 1 million the previous year ) targeted border security in the northern and eastern regions , reflecting U.S. - Kenyan cooperation in the war on terrorism .