Tom Hirsch, Berta Walder, Howard Walder, and Harish Shah were member managers in Radical Bunny LLC. Between 2006 and 2008, they raised nearly $190 million from investors in the name of Radical Bunny. Radical Bunny used that money to make loans to another company, Mortgages Limited. Mortgages Limited in turn was to make loans to developers and real estate buyers, who were to secure the repayment of the loans by deeds of trust on the land the borrowers developed or bought. The investors in Radical Bunny were to be named as beneficiaries of such deeds of trust. The LLC’s member managers sent each investor a document titled “Direction to Purchase,” which constituted the investor’s contract with the member managers. The monetary investments each investor made pursuant to the Direction to Purchase were used for the same purpose that is, to allow Radical Bunny to make loans to Mortgages Limited. The managers promised the investors a profit of 11 percent interest annually on their investment. The 11 percent annual payments were to be paid by Radical Bunny. All the investors’ profits were to come from the member manager’s efforts. Investors did not exercise any control over the loans; only the managers had the authority to manage the investments. Were the investors’ purchase of LLC interests in Radical Bunny LLC held to be securities under the Securities Act of 1933?