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Not sure why everyone is speculating. I'm also not sure why the consensus of people on an internet board would justify a conclusion.
SEC Page on Insider Trading
Or just email the SEC.
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you understand the SEC definition isn't necessarily correct, don't you? The SEC is constantly trying to push the boundries in defining IT, and occasionally gets its wrist slapped by the courts for doing it. The SEC believes that a vague definition will prevent more bad acts, and a strict, consistent defintion will open unforseen loopholes.