Utley offered to sell one-half acre beachfront lots to the public at $50,000 per lot. After the completion of a sale, Utley offered to perform services as a general contractor for purposes of building a shore house on the lot. Twenty percent of the owners hired Utley to build the houses, but the other 80 percent either hired their own contractors or left the land undeveloped. Once the houses were built, Utley offered to find a buyer for a 10 percent commission on a complete sale.