I would like to see what a court of law would think about this. Regardless if DL is considered an insider or not for accounting purposes he is an insider with respect to non public info. Did he break any laws? Did he tip or advise others or even use the insider knowledge for his own gain. To me he is a quasi director.

Insider trading regulations not only applies to the typical insider, but it also
applies to employees, such as engineers, accountants who acquire material information
from a corporate source. These persons are considered “temporary insiders.”