Yours is as good a theory as any. I would add that another possibility is that they are trying to control the float through a hedge fund. Only after acquiring enough shares will they leak them into the market and drive up the share price. Rinse and repeat. As long as we're stuck in the pinks, SEC doesn't care what happens and everyone knows it. They have some proxy good boys on the staff whom never get deleted. Their job is to serve up softballs for the bashers while selling the company, All the while, they hold millions of shares which they can use to play the game from the inside.