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Insider Trading, Once Removed

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The Securities and Exchange Commission (“SEC”) charged Charles L. Hill Jr. with insider trading in connection with his purchase of shares of Radiant Systems stock the day before a merger was announced. Mr. Hill became aware of the material non-public information through a friend who obtained the information from his close friend, the Radiant COO. Mr. Hill had made no equity purchases in over four years before buying $2.2 million of Radiant stock before the announcement. The day after the merger was announced Mr. Hill sold his entire equity interest for a profit of approximately $744,000. In the eyes of the SEC, trading on material nonpublic information learned from a third party is no different from trading on information received directly from an insider.