Section 17(a)(2) and (3) of the Securities Act "(2)to obtain money or property by means of any untrue statement of a material fact or any omission to state a m

Section 17(a)(2) and (3) of the Securities Act "(2)to obtain money or property by means of any untrue statement of a material fact or any omission to state a material fact necessary in order to make the statements made, in light of the circumstances under which they were made, not misleading; or (3)to engage in any transaction, practice, or course of business which operates or would operate as a fraud or deceit upon the purchaser."