The only reason ST was selling 2.85 billion shares is because their customers were selling the inflated shares in their account [Section 97 of the amended complaint]. They say their customers initiated sell orders to the tune of almost 3 billion. Technically, ST tried to sell those shares to some MMs, but it was on their customers' behalf. Wouldn't that be individual selling?
"98. Based on these orders, between 11:05 a.m. (CST) and 11:18 a.m. on December 6,2010, Scottrade delivered to Knight offers to sell approximately2.85 billionGeoBio commonshares in six lots, the smallest of which was for one million shares. Each lot was offered toKnight on terms such that a person knowledgeable about GeoBio and the market for its sharesshould have known that either or both the quantity or the price at which the offer was made waswildly inconsistent with the market for GeoBio shares."
