conclude that those share purchases were made on the basis of
 In addition, L.K. admitted that he received information
from Azeff about Masonite and made share purchases as a
result. L.K.’s purchase represented the largest position that he
had taken in any company up to 2004.
 Further, L.K. also admitted that, after he received the
information from Azeff about Masonite, he communicated that
information to Miller. Minutes after L.K.’s purchases of Masonite shares, Miller began to buy Masonite. Further, on November
24, 2004, Miller e-mailed a client about Masonite. He said that
he had “a tip” that there would be a cash takeover of $40, and
that the takeover would come before Christmas. That information, of course, accords directly with the material non-public
information that Finkelstein passed to Azeff.
 Azeff and Bobrow attempt to undermine the Panel’s conclusions by submitting that the Panel reasoned in reverse from
the content of Miller’s e-mail to conclude that Finkelstein knew
the details of the material non-public information. As I have
already dealt with above, Miller’s e-mail is not the foundation
upon which the Panel came to that conclusion. The conclusion
that Finkelstein knew the material non-public information is
based on other facts.
 As I have also reviewed above, the Panel’s conclusion that
Finkelstein tipped Azeff is a reasonable one. Among the reasons
in support of that conclusion are the significant purchases of
Masonite shares by Azeff and Bobrow. The Panel did not accept
their contention that these purchases were routine or usual —
a finding that was open to the Panel on the evidence. In a similar vein, the Panel did not accept the contention by Azeff and
Bobrow that the purchases were based on prior research, that
they had undertaken on Masonite, because that contention
failed to explain the sudden and significant purchases.
 The further contention by Azeff and Bobrow, that the
Panel’s conclusion that Azeff tipped L.K. is flawed, is advanced
by ignoring material facts, the most obvious of which is that L.K.
says that Azeff gave him the information about Masonite. It also
ignores that L.K. says that he told Miller about Masonite, and it
ignores the fact that the details that Miller had about Masonite
mirror the details of the material non-public information that
 Azeff and Bobrow say that Azeff had no motive to tip L.K.
That submission ignores the fact that motive is not a requirement for a finding of tipping under s. 76 of the Act. In any event,
to the degree that the presence or absence of motive is relevant,