> In this case, once Ying correctly deduces that Equifax is the company involved, he needs to block himself from trading and, if he has a question about his eli

> In this case, once Ying correctly deduces that Equifax is the company involved, he needs to block himself from trading and, if he has a question about his eligibility to trade, to seek personal counsel and/or the advise of his compliance officer. See I think the issue here is that when he made the trade he didn't know that Equifax was the company involved, he just made an educated guess with no confirmation from anyone. The question will be whether the pieces of the puzzle he did have access to were "material non-public information" or was it only that he guessed correctly (if he was later shown to be correct but didn't know at the time). The reporting makes it seem like the project was well known to non-insiders so its questionable that just knowing about the project and then guessing can be insider trading. A lot of stock analysts are worried about the implication of situations where reading a lot about a company, inferring that you expect something might happen, and trading on an educated guess becomes a crime if you're right.