edit: Doma, please ask 24 for a more detailed discussion on securities law.
the Mass complaint clearly alleged a "failure to disclose adverse facts known [to the insiders]."
it is by negative implication where insiders do not fully disclose all material facts & subsequently sell securities, such acts can be construed as "insider trading." you seem to only understand insider trading as knowing about good news in advance & trading ahead of that news. the inverse is also true, if an insider knows of potential "bad" news & sells into an artificial inflation of the price (a la Sam Waksal @ Imclone), that too is considered insider trading.
go back & read the cited SEC language you just posted & compare it to the complaint/s... a good place to start is para. 16 "fraudulent scheme and course of business" of the Mass complaint.
these are not "my" facts Doma, they are the facts (at least as they are alleged in the pleadings).
i can't believe this is the first time you have contemplated this aspect of the investigations.
what did you think it was all about?
edit: Doma, despite you considering me Wave's antiChrist or something, you might take some cold comfort from the fact that i have repeatedly reserved the possibility that Wave & its principles could be fully exonerated by the SEC. additionally, i also have posted that Wave could quickly settle the class action claims (& such a settlement would likely be of the "Wave does not admit or deny the allegations" variety.)
but none of that changes the fact that they are being investigated...
good luck.
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