General European Strategic Invt's Inc (GESI)

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You are correct, with the exception of Gordon. He is exempt as an officer.

However, many of us have been harping on the SEC to enforce the misuse of the PSLRA.

Recently, the SEC commented on a registrant as follows:

We note disclosure that certain statements are forward-looking statements within the meaning of Section 27A of the Securities Act of 1933 and Section 21E of the Securities Exchange Act of 1934. These safe harbor provisions do not apply to statements made by penny stock issuers. In future filings, please remove the reference to the safe harbor provisions for the Private Securities Litigation Reform Act of 1995, as you appear to be an issuer of penny stock. See Section 27A(b)(1)(C) of the Securities Act, as amended and Section 21E(b)(1)(C) of the Exchange Act, as amended.

Gordon, nor his associates that represent him can rely upon the safe harbor provisions under the PSLRA as follows:

Safe Harbor does not apply to penny stocks.

15 U.S. Code § 77z–2 - Application of safe harbor for forward-looking statements

(b) Exclusions
Except to the extent otherwise specifically provided by rule, regulation, or order of the Commission, this section shall not apply to a forward-looking statement—

(1) that is made with respect to the business or operations of the issuer, if the issuer—
(A) during the 3-year period preceding the date on which the statement was first made—
(i) was convicted of any felony or misdemeanor described in clauses (i) through (iv) of section 78o (b)(4)(B) of this title; or
(ii) has been made the subject of a judicial or administrative decree or order arising out of a governmental action that—
(I) prohibits future violations of the antifraud provisions of the securities laws;
(II) requires that the issuer cease and desist from violating the antifraud provisions of the securities laws; or
(III) determines that the issuer violated the antifraud provisions of the securities laws;
(B) makes the forward-looking statement in connection with an offering of securities by a blank check company;
(C) issues penny stock;

http://www.law.cornell.edu/uscode/text/15/77z-2