another matter to commit a significant amount of money based
on that tenuous information. The United States Court of
Appeals for the Eleventh Circuit put the proposition well in its
decision in U.S. S.E.C. v. Ginsburg, 362 F.3d 1292 (C.A. 11th Cir.
2004), at p. 1299:
The larger and more profitable the trades, and the closer in time the trad-
er’s exposure to the insider, the stronger the inference that the trader was
acting on the basis of inside information.
 In the case of Legacy, in the five trading days between
July 5 and 12, 2007, family and clients of Azeff and Bobrow
invested $3,058,387 to buy 254,200 units of Legacy.
 Finally, some additional evidence that these purchases
were the result of tipping can be found in the e-mail that one
of Azeff’s clients, who the Panel found Azeff had tipped about
Legacy, sent to Azeff about three hours before the Legacy trans-
action was to be publicly announced. The e-mail said simply,
 The Panel’s conclusion that Azeff and Bobrow received
material non-public information, and used that information to
tip others, is a reasonable one that was open to the Panel based
on the evidence.
C. Miller — Masonite
 The only transaction with respect to which Miller was
found liable is the Masonite transaction. The Panel found that
Finkelstein passed material non-public information to Azeff
who, in turn, passed it to L.K. who, in turn, passed it to Miller.
 I have already dealt with the allegations regarding
Masonite as they relate to Finkelstein and Azeff. In the course
of that analysis, I mentioned that L.K. admitted that Azeff provided the Masonite information to him. L.K. also admitted that,
after he spoke with Azeff, he called Miller. L.K. recalled that he
told Miller that Masonite was “in play” and that Miller and he
talked about a 20 per cent premium. The difference between the
trading price of $34 and the actual purchase price of $40 is about
20 per cent.
 Miller did not give evidence before the Panel. Rather,
portions of his compelled interview with the respondent were
placed into evidence. There was no objection to the Panel receiving the evidence of Miller (or Cheng) in this fashion. However,
at the time that the matter was discussed before the Panel,
counsel for Azeff and Bobrow raised an issue. The brief exchange
with the Panel was as follows: