I personally think people scream about that way too much. I think it can happen but I doubt it happens as much as you hear it here on ihub. The theory is that the mm doesn't want to execute the trade at that particular price so they put up a "fake wall" to make it look like there are loads of shares to get through. If for instance the ask is huge with large amounts and a lot of mm's lined up and then all of a sudden a few buys come in and the ask moves up, it is thought that the wall is fake.
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