Christopher Lowe (defendant) had been a registered investment adviser until 1981, when the Securities and Exchange Commission (SEC) (plaintiff) revoked his registration. Lowe then began to print an investment publication that included investment strategies and suggestions. This publication provided impersonal financial advice, and was distributed to the general public. The SEC then commenced this action against Lowe, alleging that he was not permitted to print the publication in question as it was providing investment advice by unregistered advisers, in violation of § 203(a) of the Exchange Act. The court of appeals ruled in favor of the SEC, and the United States Supreme Court granted certiorari.