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It was the "villain" of its own movie, and barely had any screen time;
Team Preview kinda makes Disguise pointless;
Locked behind a event in BW1, requiring two NDS systems, a copy of HG/SS with the the three shiny Johto beasts to get;
Zorua locked behind another event, requiring Celebi from HG/SS;
Liretally only appear at the very end of BW1, in N's and Ghetsis team, not even an ace. Lucario had three major appearances during D/P/Pt (ace for Maylene, Riley's Lucario, and Cynthian's Lucario);
To japanese and maybe scary for little kids. Lucario had a more universal appeal;
Despite all the shit it got, Zoroark still have a considerable large fanbase (despite 90% being nsfw)