Attention Securities Litigators: "HFT Quote Churn "Spam" Soars To Record As Volume Plummets"

I'm pretty sure that under both the '33 and the '34 Acts this behavior is illegal. Here's '34:

Securities Exchange Act of 1934, Section 9 -- Manipulation of Security Prices

a. Transactions relating to purchase or sale of security

It shall be unlawful for any person, directly or indirectly, by the use of the mails or any means or instrumentality of interstate commerce, or of any facility of any national securities exchange, or for any member of a national securities exchange--

1. ...
   
2. To effect, alone or with one or more other persons, a series of transactions in any security registered on a national securities exchange or in connection with any security-based swap agreement (as defined in section 206B of the Gramm-Leach-Bliley Act) with respect to such security creating actual or apparent active trading in such security, or raising or depressing the price of such security, for the purpose of inducing the purchase or sale of such security by others.

From ZeroHedge:

....3. SPY - Quotes Per Trade - New All Time Record.

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4. SPY - Quotes Per 100 Shares - This ratio leaps to record highs.

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