Lawrence D. Polizzotto, a former vice president at First Solar Inc., spoke in one-on-one phone calls with some analysts and investors. He stated that the company was unlikely to receive a much-anticipated loan guarantee from the U.S. Department of Energy. The next morning, this information was disclosed in a press release. The stock price dropped 6 percent. Has Polizzotto violated any SEC rules or regulations? [In the Matter of Lawrence D. Polizzotto, Adm. Proc. File No. 3-15458 (September 6, 2013)]