Selling short against the box. Holders of restricted 144 shares often use offshore or Canadian brokerages to sell short against their restricted 144 shares. This is called shorting the box (the 144 shares are "in the box") and is a synthetic sale of a long position, but it shows up as a short sale on SHO.
The 144 shareholders who shorted the box would appear to uneducated people as the unicorn "naked shorts" when they look at SHO numbers or blue sheets.
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