He sold "UNRESTRICTED" shares! Need to see the quote again?
During the Relevant Period, the Entity Defendants, acting through and under the control of Kramer, purchased, held, and sold 100’s of billions of unrestricted, newly issued shares of common stock of microcap issuers
He isn't being charged with anything aside from being an Unregistered Securities Dealer. No naked short selling and no selling of restricted shares!
Whether you realize it or not, this just blew the DBMM / Kramer naked short fable out of the water!