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Many countries use U.S. insider trading doctrine as a model, in part as a result of historical and political factors and in part because the United States is seen as a market leader--an early adopter with a well developed, disaggregated, public securities market. Yet, despite these convergent beginnings and a general agreement on the nature of the regulated conduct (i.e., prohibiting securities trading by insiders possessing material nonpublic information), operative insider trading rules in the United States (as a rule originator) have evolved to protect different interests and regulate different specific market activities than insider trading rules in other countries. Using existing insider trading law and regulation in the United States, Germany, and Japan, this paper (a) identifies the common roots and divergent evolution of insider trading doctrine in these nations, (b) articulates ways in which differences in current insider trading doctrine may be meaningful, and (c) isolates possible reasons for the existence and persistence of the observed doctrinal divergence. Divergent political, economic, and societal histories, and differences in legal systems and traditions, are at issue in the analysis. ..PAT.-Unpublished Manuscript [ABSTRACT FROM AUTHOR]