I could be wrong, but I believe that had Friedland acted properly the company would have had to issue a form 4-K each time he made a sale. I no of none such filings, so I don't believe the company was ever told he sold shares, and I'm in doubt that they ever knew the shares were transferred to him by the transfer agent.

I don't know if Friedland was ever paid cash by the company, but even a payment in shares and him being listed under management on their website certainly should have put him in a position where share transactions needed to be reported IMHO. I believed he managed to do this all by himself. If Ziv had played a part, I believe the SEC or Israeli authorities would be going after him.

Gary