Overstock is big board. I believe their problem resulted from options MMs using their exemption.
It's also a pretty crappy company. If Patty Byrne had spent more time on business, and less whacking the "Sith Lord", he might not have had to worry about any of it.
Overstock.com is an excellent example of a company with crooked, inept management that has used the "naked short seller" scam to distract investors from shoddy financials and executive misconduct.
No company, any where, at any time, has ever been harmed by naked short selling. There are no exceptions.