See the kinds of criminal enterprises NASDAQ uses these days as Market Makers. Google: Citadel Securities, Quantlab Loom Over Trial Probing Whether Human Traders Tricked Machines:
"CHICAGO—Citadel Securities’ headquarters stands across the street from this city’s federal courthouse. The high-speed trading powerhouse had an even closer view when one of its traders began testifying Friday in a criminal trial over market manipulation known as spoofing.
Citadel Securities and Quantlab Financial LLC, another electronic trading firm that uses computer models to automate buying and selling, have loomed over this week’s trial. The firms were allegedly victimized by the spoofing of two former Deutsche Bank precious-metals traders, who are fighting fraud charges against them.
Attorneys for the two former traders, James Vorley and Cedric Chanu, deny the charges and have attacked a basis for the case—that the men defrauded “supercomputers” by flooding the market with phony orders that gave a misleading picture of supply and demand, also known as spoofing. The orders were in fact genuine because any participant, defense attorneys countered, could trade with them before they were canceled.
Some critics of the Justice Department’s spoofing crackdown say prosecutors have turned routine behavior into a crime on a par with insider trading, while the alleged victims are often computerized trading firms that update or cancel orders in milliseconds. Many investors say the enforcement is justified because rampant spoofing undermines the integrity of prices.
Since Congress outlawed the practice in 2010, the Justice Department has charged 20 traders with spoofing-related crimes and eight have pleaded guilty."
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