I'd disagree with that statement. It may as well be deliberate "simulation" of sudden active trading, that just sets off all kinds of trade/volume alarms, which leads to speculative buys. Surge lasts for 15min to an hour, during which the "instigator" may cash out solid 25% (like INAR today). Kinda like snow-ball effect, when over-optimistic newcomers think somebody knew something and bought a boat-load at ASK, they buy at ASK, others see "fight" and join, until the pool of buyers drains.
INAR showed up on OTCBB-60 Actives at 09:31:25
Just in one week a lot of my positions had huge volume spikes (5x-10x avg) with no news, and then next day - no volume, and pps drops.
So, don't hold your breath