I did some research on this because your question was a really good one. I didn't find any particular rule of 30 days but I did learn the following:
"SEC Rule 10b5-1 clarified that the prohibition against insider trading does not require proof that an insider actually used material nonpublic information when conducting a trade; possession of such information alone is sufficient to violate the provision, and the SEC would infer that an insider in possession of material nonpublic information used this information when conducting a trade. However, SEC Rule 10b5-1 also created for insiders an affirmative defense if the insider can demonstrate that the trades conducted on behalf of the insider were conducted as part of a pre-existing contract or written binding plan for trading in the future." (quote From Wikipedia--verified by going to the SEC website.).
In summary, the key question in this analysis is the knowledge an insider possesses and when they possess it.
Going back to the timeline, the Sacks conference was 3/19 and the purchases by insiders were 3/20. Since they went to a partnership conference, a reasonable inference would be that a partnership was not already in place. Further, Punit went to Boston for face to face meetings the following week. If those meetings stemmed from partnership interest after the conference any information gathered there or any tenative agreements make were made after the insider purchases. Maybe Punit and co had a good feeling that the Sachs conference would lead to partnership interest so he and co wanted to buy those shares well before any insider knowledge was gained as result.
Seems like something he would do especially since his amount of money invested is exactly the same as his bonus he got from ONCS. Further, the other purchases were quite small. Further,this would also point to the fact that Punit invested when he had extra money as apposed to insider knowledge. Finally, it was smart to say many many times to investors that they are going to do combination trial with anti-PD1. Also shows an intent to communicate their plans to the investor.
Can't wait to find out. Thoughts?
