There is likely no MM manipulation here, IMO, for reasons I've already cited. Pinksheets explicitly states "no firm is making a market in this stock". It could not be any clearer.
I suppose "manipulation" is relative to a degree in that "slapping the ask" to cause the price to go up could also be considered manipulation. But, IMO, typical MM tricks like dropping the bid is not happening here. We are trading with actual open market buys and sells here.