Normally, only market makers could/would short a penny stock. But if someone bought up 1,000,000 shares or more last fall when ATTBF was trading around $.01, they could easily manipulate the price by strategically dumping shares into either the bid or the ask. Keep in mind our float is only around 20 million shares. If, let's say the bid price was at $2.00 and the ask were $2.02 and under the $2 bid down to $1.85 people had placed orders for a total of 50,000 shares, you could sell 50,000 shares at market, driving the price down to $1.85 and start a panic sell. Once the price is low enough, you buy back your shares and start the process in the other direction.
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