It may be a bit more complicated than that, but in essence you are right. Buybacks cannot be done in the 1st or last (1/2?) hour of trading and they must hit the bid. (That way they can't drive the pps up intentionally)
btw - I spoke with someone last night who told me that they were buying significant size blocks everyday. Their plan is to convert to PDR's and resell.
Were they pulling my leg? Time will tell, but someone is buying this daily 'dump' OA keeps pointing out. We all have our own opinions as to who is selling and who is buying.
If it's the company selling and retail buying, we'll see an R/S or maybe even a reverse merger before this is over.
If it's a pre-arranged MM cover w/ a shareholder who had restricted shares, then the buyer may well be someone who is close enough to the situation to recognize that when the 'dumping' is done another run is coming.
Remember, this thing sat at .0001 for a year last time before they ran it to .008 - ($25k turned into $2M)
Rinse and repeat? All I can say is that they do it all the time.