However, shorting a fundamentally worthless security, whether you do it "naked" or "covered", has already been established by legal precedent not to be manipulative.
You seriously need to examine the Scattered/LTV case.
"The penny stock investor may be the most dangerous creature in the investment world, at least to himself.[...]His hypocrisy becomes most apparent when he then blames his losses on the greed of others." Robert C. Dugan, Director - JRM Capital