Zion Oil & Gas Inc (ZNOG)

[microcaps1]

i noted earlier before having this info that zn's 10k came out Mar 12-the beginning of the period during which the lawsuit claims "Materially False and Misleading Statements'

the Mar 12 10k had the following language and the 10q for period ending mar 31 had the same or similar following language:
"A. Litigation
From time to time, the Company may be subject to routine litigation, claims, or
disputes in the ordinary course of business. The Company defends itself
vigorously in all such matters. In the opinion of management, no pending or
known threatened claims, actions or proceedings against the Company are
expected to have a material adverse effect on its financial position, results of
operations or cash flows. However, the Company cannot predict with certainty
the outcome or effect of any such litigation or investigatory matters or any other
pending litigation or claims. There can be no assurance as to the ultimate outcome
of any such lawsuits and investigations."


so they are saying zn knew or should have known of sec investigation and yet said, "no pending or known threatened claims, actions or proceedings against the Company are
expected to have a material adverse effect on its financial position'

zn had no knowledge of a pending or known investigation-pandas tweets and whatever dont give rise to such knowledge-there are several reasonable paths which could be the outcome of "This exemption protects from disclosure records compiled for law enforcement activities'

1)could mean statistical purposes for various reasons such as sec rulemaking
2)a tighter circle re a class of companies
3)a tighter circle re zn or companies zn does business with etc
legally the fuzzy info on the tweets does not give rise to notice of an sec investigation-only an official notice from sec or a court could do that and there was no such notice til june 21,which notice zn duly filed/posted within the prescribed 20 day or more time period to respond

the court would have to change legal rules or statutes to impose liability
thats why the ambulance chasers are asking for a jury trial-so the average member of society who has no knowledge re these things may be influenced by plaintiffs histrionic court tactics-



Materially False and Misleading Statements Issued During the Class Period

19. The Class Period begins on March 12, 2018, when Zion filed an annual report on
Form 10-K with the SEC, announcing the Company’s financial and operating results for the
quarter and year ended December 31, 2018 (the “2018 10-K”). The 2018 10-K advised investors
that “Zion’s vision . . . of finding oil and/or natural gas in Israel, is biblically inspired”, citing
“biblical references alluding to the presence of oil and/or gas in territories within the State of
Israel that were formerly within certain ancient biblical tribal areas.”

20. In the 2018 10-K, under the heading “Note 10 – Commitments and
Contingencies”, Zion provided merely the following non-specific representation with respect to
the probability and/or impact of regulatory investigations involving the Company:

A. Litigation
From time to time, the Company may be subject to routine litigation, claims, or
disputes in the ordinary course of business. The Company defends itself
vigorously in all such matters. In the opinion of management, no pending or
known threatened claims, actions or proceedings against the Company are
expected to have a material adverse effect on its financial position, results of
operations or cash flows. However, the Company cannot predict with certainty
the outcome or effect of any such litigation or investigatory matters or any other
pending litigation or claims. There can be no assurance as to the ultimate outcome
of any such lawsuits and investigations.




the info in no 3 does not put zn on notice of an sec investigation

"This exemption protects from disclosure records compiled for law
enforcement activities."
so what -that could mean a number of things -its not the same as saying zn is under investigation-and even if it had said that zn is not legally notified of an investigation until they receive an official notice from the sec-which was not received til june 21

then legally under court rules and statutes zn had at least 20 days to respond-and zn did respond publicly by filing the 8k july 11 re the sec non-public fact finding investigation

"From this, the Twitter user FuzzyPandaShort concluded that “Zion has
an Undisclosed SEC Investigation.”

so what -neither pandas nor mine nor yours nor santa claus's interpretations are law
and panda also falsely presumed zn knew of an investigation


23. The Twitter post highlighted language from the SEC stating that “[w]e are
withholding records that may be responsive to your request under 5 U.S.C. § 552(b)(7)(A), 17
CFR § 200.80(b)(7)(i). This exemption protects from disclosure records compiled for law
enforcement activities.” From this, the Twitter user FuzzyPandaShort concluded that “Zion has
an Undisclosed SEC Investigation.”
24. On March 27, 2018, Zion posted a statement on Twitter in response to
FuzzyPandaShort’s post, unequivocally stating that “There is no SEC investigation. Merely
indicators of a routine FINRA questionnaire that’s standard after a steep rise of our stock
recently.” (See Fig. 2.)
(Emphasis added.)