The president of Biltmore Farms, LLC cooks up a scheme to raise money for the business. He proposes Biltmore Farms sell cows from its herd of 800 Jersey dairy cows to investors for $1,000 each. Biltmore Farms will retain possession of the cows. Biltmore Farms employees will milk the cows and process the milk into a variety of dairy products. Each investor will receive the right to a small percentage of the profits from the dairy farm operations. They will have a right to have their cow pointed out to them on official sanctioned tours, but otherwise will have no rights in the cow (nor any related obligations). Is this a security under the '33 Act? Explain.