If I decide to start trading in Zenith,our company, here in Canada as an OTC stock and say call a market $1 BID Offered 1.50

  that would be legal I think.Therefore if dealers in the US started this had some shares I guess that is ok too.Zenith itself would not be involved.The only real way to figure this out is through the Transfer agent.If the shares in ZHLCF are our company they would have to go through the Agent.