Absolute Activist Value Master Fund Ltd. v. Ficeto

Absolute Capital Management Holdings Limited (plaintiff) alleged that its officers and broker-dealers (defendants) defrauded it by causing it to buy shares of penny-stock companies and then inflating the prices for profit. The transactions involved foreign securities, raising the question whether U.S. securities law reached them.

Whether securities transactions not traded on a domestic exchange are 'domestic'-and thus subject to U.S. securities law-if irrevocable liability is incurred or title passes within the United States.