Hugo wishes to raise money for his restaurant. He offers to sell stock to his brothers, sisters, aunts, uncles, and cousins. The offering is made by telephone to each of the investors and amounts to a stock offering in the total dollar amount of $1.5 million. The offering is made to a total of 38 family members and no notice is given to the SEC. Is this a permissible exempt offering under the federal securities laws? Explain.
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