Van...you are right...a Warrant is NOT an Equity position. Just think about it...the warrant expires and is not exercised in the expiration time-frame ... they would have zero interest in XXII.
...they don't have to report an "Equity" interest or position they don't have.
...if they exercise warrants on a "cashless" basis...they might not have to report the transaction since it could be considered a sale of the warrant, not the stock...but I believe that would be a very specific accounting rule I do not have knowledge of.
...finally...exercising of warrant where they take delivery of the stock could be a reportable event...and whether they are "mandated" to publicly disclose is probably governed by the % of their holdings.
...IMHO...the clearest indication of how many warrants Sabby still possesses is the Company's reporting on the general number of outstanding warrants...and we would have to guess as to "who" exercised them if the number has diminished.
News 
Market Data 
Discover 
