You are a senior portfolio manager at a southeastern asset management company. Your brother is a senior scientist working on a group of projects at MBC, a medium-sized biotech company near San Diego. One of his projects is the late-stage trial of a potential blockbuster drug. You speak to him rather infrequently, but know about his involvement in the drug trial. Your brother knows that you are a portfolio manager, but has never asked and does not know whether you own any MBC stock in your portfolios. You call him from your car phone one afternoon after the market has closed to schedule a dinner with him on an up-coming West Coast trip. In passing, you ask him, “How’s work going?” He replies, “So-so. Things are not great on one of my big projects.” Right after he says that, you lose cell phone service and the call is dropped.

The next morning you tell two of your portfolio-manager colleagues about the conversation with your brother. All three of you decide to sell out all the MBC stock in the various portfolios that you manage. Two weeks after your sales, MBC announces that the drug trial has failed, and its stock falls significantly. Thanks to the sales, your clients avoid $20 million in losses. 

Has insider-trading occurred? Explain why or why not.