there was nothing to indicate Matt Brown used Ihub to manipulate penny stocks.
j. On or about December 7, 2006, defendant BROWN communicated via instant message with P.D. regarding P.D.'s posting of messages concerning GI-3's stock on IHUB internet message boards.
m. On or about December 7, 2006, P.D. communicated via instant message with N.M. asking N.M. to post on internet message boards that there was a "short" in GH3 stock.
n. On or about December 7, 2006, defendant BROWN communicated via instant message with P.D. wherein P.D. told defendant BROWN to have GH3 issue another press release indicating that GH3 had ordered a non-objecting beneficial owners ("NOBO") list from its transfer agent to address unexplained short positions in GH3 stock and suggesting language for that press release.
o. On or about December 8, 2006, GH3 issued a press release about ordering a NOBO list, using some of the language suggested by P.D. in the December 7, 2006 instant message.
Looks to me as if Matt and the others utilized IHUB as a means to give the false belief that there was a significant short positiona nd then worked together to draf a PR that matched the posts that were put on IHUB. That certainly qualifies as using IHUB to manipulate the stock price.