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Securities and Exchange Commission v. Ralston Purina Co., 346 U.S. 119 (1953), was a case in which the United States Supreme Court held that a corporation offering "key employees" stock shares is still subject to Section 4(1) [Now Section 4(2)] of the Securities Act of 1933. Rule: Section 4(1) [Now Section 4(2)] of the Securities Act exempts "transactions by an issuer not involving any public offering" from the registration requirements of Section 5.