Insider Who Did Not Trade but Tipped Friend, Charged and Pays

Insider trading is a long-time key focus of the Commission’s Enforcement Program. Despite the fact that the Commission has repeatedly brought insider trading cases for both small amounts of ill-gotten gains and large amounts of trading profits  many still believe that it is most difficult to get caught.  Stated differently, many still believe that it is easy to get away with it and very profitable if you can. To be sure, it can be very profitable since it is essentially cheating the trading market and those participating in it.  At the same time, it is not nearly as difficult to get caught as many believe.  If you think so just take a look at the cases discussed below.  SEC v. Tavlin,  Civil Action No. 22-cv-01723 (D. Minn. Filed July 6, 2025).

Named as defendants in the action are: Doron A. Tavlin, is a former. executive; Afshin Farahan, a friend of Mr. Tavlin; and David Gantman, a friend of Mr. Gantman.

Defendant Tavlin is a former executive of Mazor Robotics Ltd. While working at the firm he was involved in discussions regarding the potential acquisition of Mazor by Medtronic PLC.  In August 2018 Mr. Tavlin told his friend, Defendant Farahan, about  discussions he participated in at his employer regarding a corporate transaction.  Mr. Farahan then purchased shares.  He in turn then told his friend, Defendant Gantman about the potential deal.  Mr. Gantman made multiple purchases of stock. Following the deal announcement, Mr. Gantman and Mr. Farahan had combined trading profits of about $500,00.

After the purchase transactions and during the Commission’s pre-complaint filing, Defendants took steps to conceal their actions.  Nevertheless, each was charged by the Commission with insider trading.  See also SEC v. Tavlin,  Civil Action No. 0:22-cv-01723 (D. Minn. Filed July 6, 2022).

Mr. Travlin, who did not trade was  still changed in this action.  Since he did not trade he had no insider trading profits.  His friend did, however, give him a $25,000 kickback from the trading profits.  This action charged him with violations of Exchange Act Section 10(b) and Rule 10b-5.

To resolve this matter Mr. Travlin consented to the entry of a permanent injunction based on the provisions cited in the complaint.  He also paid disgorgement of $25,000 – the amount he was paid—plus prejudgment interest of $7,875.  The case was uncovered and developed by the Commission’s enforcement division using data analytic tools to detect the suspicious  trading patterns.  See  Lit. Rel. No. 26367 (August 6, 2025).