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A comment on Confirmed: Walmart buys Jet.com for $3B in cash. Parent comment

Re:Confirmed: Walmart buys Jet.com for $3B in cash by nv-vn on Monday August 08, 2016 @12:06PM (#12248814)
Well he was just referring people to sign up for the website. The money was money he spent advertising the website(?), so the money only went to getting new members. The stocks were given as the reward for the most sign ups, not in exchange for money.
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Re:Confirmed: Walmart buys Jet.com for $3B in cash by elbasti on Monday August 08, 2016 @12:27PM (#12248940)
The point is that the stock was exchanged for something (referrals, marketing, etc), and that the contest was announced (ie, general solicitation). That no cash traded hands doesn't matter.

There is precedent of an almost identical enforcement action by the SEC, but my google fu is failing me.

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Re:Confirmed: Walmart buys Jet.com for $3B in cash by 6clotr1ckg on Monday August 08, 2016 @05:06PM (#12250877)
Can a startup publicly recruit with the promise of stock as compensation?
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Re:Confirmed: Walmart buys Jet.com for $3B in cash by throwawaylalala on Monday August 08, 2016 @02:18PM (#12249773)
Would be Jet.com's issue, not the guy.
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Re:Confirmed: Walmart buys Jet.com for $3B in cash by elbasti on Monday August 08, 2016 @03:20PM (#12250219)
That is correct.
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