Section 12(a)(2) of the Securities Act (15 USC 77l(a)(2)) imposes liability on any person who offers or sells a security by means of untrue statements or concealments. In Pinter v. Dahl, 486 U.S. 622, 643, 647-48 (1988), the Supreme Court held that a person may be liable as a “seller” under the predecessor version of § 12(a) if the person either: (1) passes title to the securities to the plaintiff; or (2) “engages in solicitation,” i.e., “solicits the purchase [of the securities], motivated at least in part by a desire to serve his own financial interests or those of the securities owner.” This decision holds that to fit within the second part of this definition, the solicitation need not be directed toward the plaintiff or any particular potential buyer, but can be solicitation by internet posting or YouTube video aimed at the public generally. While the seller must have a financial interest in promoting sale of the security, the seller need not be in privity with the buyer who sues under section 12(a)(2).