In Sparhawk v. Yerkes, 142 U.S. 1, the conclusion in Hyde v. Woods was reaffirmed in respect of seats in the Stock Exchanges of New York and Philadelphia, which were then voluntary unincorporated associations, with the same provision as to membership and preference for the debts of member creditors.
In Page v. Edmunds, 187 U.S. 596, the question was whether a seat of a bankrupt in the Philadelphia Stock Exchange was property passing to the trustee under subdivision 5 of ยง 70 of the Bankrupt Act.
In Ager, a judgment creditor filed a creditor's bill in an attempt to satisfy a monetary judgment against an individual who owned no real or personal property subject to execution at law, but who owned an interest in certain patents.
Holding that because stock exchanges created property interest in seats on exchanges, they could reserve unto themselves the right to be paid first any debts owed them from proceeds received upon sale of seats
In Matter of Hellman (174 N.Y. 254) it was said, in speaking of this section of the statute: "All property having an appraisable value must be considered, whether it is such as might be taxed under the general law or not."
In Powell v. Waldron (89 N.Y. 328) it was held that a membership in the New York Cotton Exchange was property and as such passed to a receiver appointed in supplementary proceedings on an execution against the owner, and that the receiver had a right to redeem the seat when it had been pledged by the judgment debtor as collateral for a loan.