You know it's funny how from one perspective, small sells that make the price print lower are not manipulation, but the reverse IS manipulation.  I've seen sells below the bid, like the one recently for 600 shares, which netted the seller $7.20 - $9.99 = $-2.79, and occurred 1 minute before the close.  I didn't notice whether Mr. Zone thought that was manipulation.  I guess he must have missed that one.