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Quotation from Lowe v. SEC by Supreme Court of the United States
“Notably, however, those words describe the publication rather than the character of the publisher; hence Lowe's unsavory history does not prevent his newsletters from being "bona fide."”
Lowe v. SEC, Opinion of the Court (Justice Stevens), Part III (U.S. Reports text (Legal Information Institute))

Justice Stevens interprets the phrase bona fide in the statutory exclusion.
Citation: "Notably, however, those words describe the publication rather than the character of the publisher; hence Lowe's unsavory history does not prevent his newsletters from being "bona fide."" — Supreme Court of the United States, Lowe v. SEC, Opinion of the Court (Justice Stevens), Part III (U.S. Reports text (Legal Information Institute)). (id lowe-v-sec-q4)
Portrait: John Paul Stevens, SCOTUS photo portrait, Steve Petteway, photographer for the US Supreme Court, Public domain.
