They would not require a trading halt, if the response was the standard 1. The Company is unaware of any information concerning it that has not been announced and which, if known, could reasonably explain the recent trading in the Company’s securities. 2. Not applicable. 3. No. 4. The Company confirms that it is in compliance with ASX Listing Rules and, in particular, Listing Rule 3.1.
So perhaps while the company is aware of information concerning it which if known would explain the recent trading, the company will need to carefully assert that a reasonable explanation of the increased trading could be the company's initiative in investor relations (which purely confirmed what was known to the market, that negotiations were in progress) may have been interpreted by the market as confirmation that the proposed deal had been completed.
To avoid penalty, they will need to convince ASX that the market is equally informed. But if the deal is complete they will need to release that information. I imagine there are some furrowed brows at ODN.
A good response with details of a completed deal will set this alight
ODN Price at posting:
1.9¢ Sentiment: Buy Disclosure: Held