SUMMARY
This blog is written by HPQ CEO Bernard Tourillon. He has formally requested that the Canadian Investment Regulatory Organization (CIRO) investigate what he believes to be manipulative trading activity in HPQ shares. He highlights repeated patterns of spoofing and layering — where large, pre-market orders are placed and then canceled — which can distort market sentiment and drive down share prices. Mr. Tourillon argues that such practices disproportionately harm small-cap companies, eroding investor confidence and undermining their ability to fund innovation. He urges regulators to act decisively to protect shareholders, restore market integrity, and ensure a fair playing field for all issuers.
DEEP DIVE
When market manipulation becomes too obvious to ignore.
Spoofing and layering are market manipulation techniques where traders place and quickly cancel orders to create a false impression of market activity and potentially profit from the price movements they induce.
For years, I’ve been proud to lead HPQ as we push the boundaries of advanced materials research, from fumed silica production to high-performance battery technologies.
We operate in a challenging space, one where progress is measured in long timelines and incremental breakthroughs. But lately, the challenge hasn’t just been scientific or financial.
It’s been about market integrity.
In recent months, I’ve watched trading activity on HPQ’s stock that makes no sense when measured against our company’s progress.
Even as we’ve delivered milestone after milestone — pilot-scale fumed silica production, commercial evaluations with a global manufacturer, a hydrogen agreement, and a new battery development initiative — our share price has steadily declined. That disconnect alone raises concerns.
But what we’ve observed goes beyond “normal volatility.” It points to behavior that looks manipulative, targeted, and damaging to both our company and our investors.
That’s why I wrote to the Canadian Investment Regulatory Organization (CIRO), demanding immediate action.
WHAT ARE SPOOFING AND LAYERING, AND WHY SHOULD YOU CARE?
For those unfamiliar, spoofing is when traders place large buy or sell orders with no intention of executing them.
Layering goes further, stacking those fake orders at different price levels. The goal? To create a false sense of supply and demand, tricking both human traders and automated systems into reacting as if the market is under real pressure.
Here’s what we’ve seen: large, pre-market sell orders appearing at exactly 7:00 AM every day, only to vanish just before the opening bell. These aren’t legitimate trades. They’re theater designed to push sentiment down and manipulate algorithms.
And this isn’t some isolated incident. It’s been a daily pattern, concentrated through one of the biggest names in global brokerage: Morgan Stanley.
WHY THIS HITS SMALL-CAP COMPANIES HARDEST
For small-cap issuers like HPQ, these tactics can be devastating.
We don’t trade with the same volume or liquidity as large caps, which makes us far more vulnerable to these games. This isn’t just about price swings; it’s about confidence.
When investors see these phantom orders, they perceive “selling pressure” that doesn’t really exist. That drives down our share price, erodes shareholder value, and most critically, undermines our ability to raise capital to continue developing breakthrough technologies.
And that’s the part that stings most: this kind of activity actively sabotages innovation.
THIS GOES BEYOND HPQ
This issue isn’t unique to us.
If these practices go unchecked, they jeopardize the credibility of Canada’s venture markets as a whole. If investors, both Canadian and international, lose faith in the integrity of our exchanges, they’ll take their capital elsewhere. For small-cap innovators, losing that trust could be fatal.
WHAT WE’RE ASKING FOR
In my letter, I’ve formally requested that CIRO investigate these patterns of behavior on HPQ shares.
We’ve supplied detailed evidence, including screenshots, timestamps, and internal analysis, documenting exactly what we’ve observed. We’ve also asked regulators to review broader trading activity, including the use of dark pools, potential naked short selling, and coordinated disinformation campaigns.
This isn’t just a request for one company. It’s a call for accountability in our markets.
If we want Canadian venture markets to remain viable for innovators, regulators need to take these issues seriously and act decisively.
SEE FOR YOURSELF
I encourage anyone who cares about market integrity to review the evidence. You can download my full letter to CIRO [here] and the supporting documentation [here].
Our shareholders deserve transparency.
Our markets deserve fairness. And our innovators deserve a level playing field.
Over the last 35 years, Mr. Tourillon has held senior-level executive positions with extensive finance, accounting, marketing, administration, and business development experiences in diverse industries including banking, manufacturing, exploration, mining, and technologies companies. Since joining HPQ Silicon in 2006, he has participated in fundraising activities and financial transactions worth over $49 million.
