The SEC would say yes. There was an employee who worked at a rail yard who noticed certain visitors and other things and decided to buy the stock. The company was purchased shortly thereafter.

How did a couple of railroad yard workers catch wind of a multibillion-dollar leveraged buyout? The complaint says they suspected something was up when they saw “people dressed in business attire” taking tours of the rail yards. It suggests their curiosity was further piqued by a day-long rail trip the Fortress folks took in a special train car reserved for visitors.

http://dealbook.nytimes.com/2010/10/01/s-e-c-charges-railroa...