[bd_at_rivenhill]

Actually, what they've really got him on is him explaining the scheme in detail to a broker-dealer, describing it as, essentially, a conspiracy to manipulate the market and defraud other investors. This is much different than a case where all you have is trading records which might represent an algorithm detecting a reversing trend with no intention to manipulate. On the other hand, the CFTC is quite aggressive recently to deter behavior that doesn't seem particularly bad. Feels like a slippery slope from here to a place where breaking up large orders and routing to separate venues might be viewed as intent to defraud by concealing intentions.