A railroad’s employees noticed that a lot of people in suits were touring the rail yard. The CFO asked for a list of all trains owned by the company. Workers began speculating that the company might be sold and they would all lose their jobs. The company’s code of conduct made it illegal to disseminate material nonpublic information. Two employees – an engineer and a trainman – bought stock in the railroad. When the railroad did indeed change hands, they were able to sell their stock for a million dollar profit. Are the employees liable under insider trading rules?