Materially False and Misleading Statements Iss

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.
(Emphasis added.)