Levitz v. Warrington

JACKSON, Judge:

Plaintiff Gary Levitz appeals the trial court’s denial of attorney fees and treble damages sought under section 61-1-22 of the Utah Uniform Securities Act (Securities Act).1 Defendant Edward Warrington cross-appeals the trial court’s conclusion that there was a “purchase” of securities giving Levitz a cause of action under section 61-1-22. We vacate the trial court’s judgment and remand for additional findings.

FACTS

Warrington was chairman of the board and chief financial officer of Energex Corporation (Energex), a company which marketed, sold, and distributed a fuel additive…