Dunno about you, but Investing 101 tells me that there can be no buy or sell without a matching transaction. Thus you can not buy, without someone selling, and you can not sell, without someone buying, and thus a trade is made, which the volume then indicates. So again, where is your evidence against this argument? Becuase an MM doesn't sit on bid, does that mean no-one is buying, and thus magically shares are being sold to no-one? Please explain. Even an NSS requires someone purchasing the fake shares.