Not close because it does not involve a public company. Still seems shady.

Insider trading laws apply to private companies as well. (No idea about the legal questions on this particular case though)

privately held securities as well as non-equity securities can be involved in insider trading, specifically it is a fraud doctrine instead of a "publicly traded equity" doctrine, so it is quite flexible

for different reasons Carta's solicitation doesn't necessarily trigger that, by mere nature of contacting people

+1 affiliates (insider) have to certify below a certain threshold its a private buyer and a private seller so no biggie