fact that, as of July 4, any purchase of Legacy was contingent
and the market was skeptical that it would, in fact, proceed. The
price of the units had declined as a consequence. The former
contention, that Finkelstein did not possess material non-public
information, is belied by the e-mail exchanges between Finkelstein and counsel for Legacy which show that, by July 4, Finkelstein expected his client to be the successful purchaser. Indeed,
an announcement date for the transaction had been agreed to.
 It was clear on the evidence that Azeff had material non-public information regarding the Legacy transaction that he
shared with his clients, and others, who, in turn, made significant purchases of Legacy units. Finkelstein possessed that same
material non-public information, at least some of the details of
which made their way to Azeff and his clients. Based on the
nature of the information, and the demonstrated contacts
between Finkelstein and Azeff at the relevant time, it was open
to the Panel to conclude that it was more probable than not that
Finkelstein was the source of Azeff’s information.
 As with the other two instances, there is no basis for
questioning the reasonableness of the Panel’s conclusion that
Finkelstein “tipped” Azeff.
B. Azeff and Bobrow — Masonite
 As will be obvious, much of what I discussed regarding
the Masonite transaction, when I dealt with Finkelstein’s
appeal, applies to the appeal by Azeff and Bobrow. Some additional facts should be pointed out, however.
 Given both their personal relationship and their work
relationship, there was a reasonable basis for the Panel to conclude that information possessed by either Azeff or Bobrow
would have been shared with the other. In addition to the relationship basis for that conclusion, the conduct of Azeff and
Bobrow, in these transactions, is capable of confirming that fact.
 I have already set out the volume of share purchases that
Azeff and Bobrow made at the relevant times. However, that
buying continued. On November 22, 2004, Azeff and Bobrow
acquired 31,235 more shares of Masonite for another $1,064,069.
That buying represented 19 per cent of all the Masonite shares
traded on the TSX. Indeed, their buying continued until the public announcement on December 22, 2004. By then, Azeff and
Bobrow had, together, acquired 293,360 Masonite shares for a
value (before the announcement of the KKR deal) of $9,950,520
in more than one hundred accounts belonging to them, their
families, friends and clients. It was reasonable for the Panel to