This sounds like a particularly common failure mode for software engineers in dealing with the law. In software engineering, we have strict rules, and most of o

This sounds like a particularly common failure mode for software engineers in dealing with the law. In software engineering, we have strict rules, and most of our thoughts are devoted to exception handling, so we're thinking about exceptions and what the behavior of the system will be in unusual cases. Law doesn't work that way. If you try and build a clever but hacky argument they don't care. They don't say "what a clever hack, you got us, you're free to go." They arrest you and charge you and maybe after your life is ruined by the expense of your legal defense, you don't actually have to go to prison (presuming you got bail for the 12-18 months it took for your case to wend through the courts)! Congratulations, you won your case! That's the good outcome! See, the law is enforced by people, not rules- it's the police, the prosecutors, the judges and the juries who uphold the law, not straightforward and simple software code. And people (very much including juries!) can tell what the intent of a law is, and they will (most of the time) enforce the intent of that law. Schemes to try and game the laws? That looks an awful lot like a guilty conscience which is sometimes a required factor in whether a crime was committed (especially on the sorts of financial crimes we're talking about here). As for the actual law defining what public disclosure is, it's Regulation Fair Disclosure (https://www.federalregister.gov/documents/2000/08/24/00-21156/selective-disclosure-and-insider-trading https://www.federalregister.gov/documents/2000/08/24/00-2115... or https://www.ecfr.gov/current/title-17/chapter-II/part-243 https://www.ecfr.gov/current/title-17/chapter-II/part-243). As I understand it, basically, the key step is that you file a 8-K form with the SEC who takes responsibility for publishing it widely, and there are rules on blackout periods for insider transactions around the filing of those 8-K's, but I'm not a lawyer, definitely don't treat what I say as legal advice, I just had to sit through lectures on this back when I worked as an engineer for a financial firm.