If a naked short seller is correct about his or her assessment of a company, then obviously they're not going to have to cover. But it's not the naked short seller that's causing these hideous companies to get their stocks revoked.
"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