Demonstrably, provably incorrect. As you referenced, the company did file suit regarding spoofing. However, a closer look at the Complaint shows why you are wrong. I rely on the December 1, 2022, Complaint, page six (6), footnote four (4):
"Whenever reference is made to any act, device, contrivance, or scheme to manipulate NWBO securities by any of the Defendants, the allegation is intended to also include the subsidiaries, affiliates, sister companies, agents and representatives of that Defendant, whose identities and specific involvement in this market manipulation case are unknown to Plaintiff at this time. Only after discovery is taken will their identities and involvement become known." (Emphasis added).
It does not simply state that the identities of others will be uncovered, but involvement as well. This is why you are flatly incorrect that this is limited to spoofing. You are saying essentially "There is only one cause of action for spoofing." A more accurate statement is, "There is only one pending cause of action for spoofing and the preeminent securities litigation firm handling this action has already asserted that it expects to uncover additional bad actors and additional bad actions."
Doesn’t mean that it can’t expand. Also, it doesn’t mean that defamation is not potentially on the table. Once the lawyers are digging, incrementally it’s not a lot of extra work to add work on to get to the bottom of things.