Detailed Instructions: In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision. Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.
Problem:its scope to reach the facts before us, particularly since doing so would read a key element out of the text of Rule 19(a)(2)®️. Visa also relies on several cases that recite the general proposition that a party who claims title to a piece of property that is the subject of an action has sufficient interest in the action to justify compulsory joinder, and urges us to follow that reasoning here. Visa attempts to characterize this case as if it were a proceeding to determine the rightful owner of a piece of property to which MasterCard and Visa have competing claims. While we have held in cases involving this factual scenario that all claimants to the property at issue are necessary parties to the action, see, e.g., Brody v. Village of Port Chester, 345 F.3d 103, 117-19 (2d Cir.2003) (<HOLDING>); Kulawy v. United States, 917 F.2d 729, 736
Holding statements: (A) holding that land sales contracts were not securities because they involved no investment in an enterprise even if land was bought on expectation that development of the area would increase the value of the land (B) holding that in action by property owner to recover land taken by eminent domain current titleholder to land might be necessary party if district court were to restore land to plaintiff (C) holding that the owner of the land could not bring a 93a action against a prior owner of the land who was not the seller because there was no business connection between the two parties (D) holding that a cause of action for damages to property resulting from a permanent nuisance accrues to the owner of the land at the time the injury begins to affect the land and mere transfer of the land by deed does not transfer the claim for damages (E) recognizing general proposition that if land is artificially submerged for the statutory period necessary to change ownership of the land title to the submerged land is passed to the state in trust for the public
Solution:
holding that land sales contracts were not securities because they involved no investment in an enterprise even if land was bought on expectation that development of the area would increase the value of the land