SUMMARY
This blog is written by HPQ CEO Bernard Tourillon. He has formally requested an investigation into additional suspected cases of manipulative trading activity involving HPQ shares. He highlights recurring patterns of spoofing and layering, including oversized pre-market sell orders that are later canceled—observed on September 15 and 16. Mr. Tourillon calls for urgent regulatory enforcement to protect investors and uphold confidence in Canada’s capital markets.
DEEP DIVE
I’ve now submitted four formal complaints to the Canadian Investment Regulatory Organization (CIRO), the most recent focused on activity observed on September 15 and 16. What we’re seeing is no longer subtle, it’s blatant. Pre-market spoofing and layered ask walls in HPQ shares are showing consistent patterns that reflect clear hallmarks of manipulative intent.
Repetitive Behavior, Familiar Brokers
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.
On September 15, a 194,000-share sell order appeared at 4:00 PM—displayed prominently at the inside ask but canceled shortly after, with no trades executed against it despite ample trading at that price just moments before. That same day, large 200,000-share asks were layered above market throughout the session, stamped with pre-market timestamps (07:01) from Broker House 1.
Less than 24 hours later, on September 16, nearly identical activity returned.
At exactly 07:01 ET, during the pre-open, Broker House 1 again posted a 194,000-share ask at $0.195, accompanied by additional large-layered asks at $0.215, $0.22, and $0.24. These orders remained visible throughout the pre-market but were canceled or reduced prior to the open, again, without executing.
This repeated pattern gives every appearance of a coordinated strategy, not a coincidence.
This Harms More Than Just HPQ
These are not legitimate trading actions. They violate Universal Market Integrity Rule (UMIR) 2.2 by creating a deceptive impression of supply and influencing investor behavior with non-bona fide orders. In thinly traded small-cap stocks like HPQ, such tactics have an outsized impact. They shape sentiment, pressure pricing, and drive away legitimate buyers and long-term holders who perceive volatility or forced selling.
For HPQ, a company with active, multi-year R&D investments in clean technology and advanced materials, this damages more than our share price. It hinders our ability to raise capital on fair terms and erodes the trust we’ve built with our shareholder base. In the long run, it’s not only HPQ that loses, it’s every innovative company that depends on fair and transparent markets to grow.
Enough is Enough!
I’ve been patient, and I understand CIRO has a confidential process for preliminary reviews. But the repetition and precision of these trades speak volumes. They are not errors or quirks of market structure. They are strategies, executed deliberately, consistently, and without consequence.
This is no longer about protecting one company’s share price. It’s about defending the credibility of Canada’s capital markets. Regulatory delay not only allows this behavior to continue, it legitimizes it in the eyes of those who benefit from it.
I have submitted full documentation, including time-stamped screenshots, order book data, and market depth files for both trading days. I stand ready to provide anything else CIRO requires.
Download the full complaint for September 15 [here] and September 16 [here].
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.
