[HWR_14]

> or an outsider who comes across data from inside the company

Doesn't it matter how you came across that data? If you were at a coffee shop and happened to overhear a bunch of Boeing engineers talking about how they were replacing bolts with hot melt glue I thought you could you trade on that. If they explicitly told you that they were replacing the bolts with hot melt glue, then you wouldn't be able to.

[pama]

Unless you shad signed an NDA that stated they would not disclose non-public info and then told you about the glue, in which case you could still trade on it.