The tipper, 33, a resident of San Francisco, was an associate at TPG Capital, L.P., which, at the time, was an unregistered investment adviser.  Whether the associate was driven by money (he got $12K in fees) or by the "thrill of the chase," he leaked material inside information to a long-time friend who, in turn, passed the information along to others. SEC Findings and Allegations. Vinayak Gowrish, from at least December 2006 through May 2007, was in breach of a duty owed to his employer, misappropriated material nonpublic information from his employer in connection with TPG’s negotiations to acquire: (i) Sabre Holdings Corp.; (ii) TXU Corp.; and, (iii) Alliance Data Systems Corp. Gowrish allegedly tipped the confidential acquisition information to his longtime friend, Adnan Zaman who, at the time, was an investment banker at Lazard Ltd.  Zaman apparently didn't trade on this information, but instead passed it along to their 2 friends, Pascal Vaghar and Sameer Khoury.  These 2 traded in the shares of Sabre, TXU, and ADS based on Gowish's information;  they realized $375,000 in illicit profits.  Vaghar allegedly made cash kickbacks to both Gowrish ($12K) and Zaman ($78k).  Zaman "earned" his larger fee for passing along inside information on several occasions, including information from sources other than Gowrish. Court-Approved Sanctions. On 2/3/11, a federal jury found that Gowrish violated Section 10(b) of the Exchange Act and Rule 10b-5 thereunder.  Gowrish was ordered to pay $12,000 in disgorgement, prejudgment interest thereon, and a $100,000 civil penalty. These monetary sanctions have been paid-in-full. Postscript:  Sanctions to Zaman. Zaman, 31, pleaded guilty in January 2011 and was sentenced to prison for 26 months (2 years and 2 months) for his part in the insider trading scheme in which he leaked information on acquisitions to friends and shared in their trading profits.  He also had to pay $78,400 in disgorgement plus interest, and must complete 800 hours of community service.  No penalties were issued. For further details, go to:  [SEC 1940 Advisors Act Release 3347, 12/29/11].