SUMMARY
This blog is written by HPQ CEO Bernard Tourillon. He has submitted a second request to the Canadian Investment Regulatory Organization (CIRO) to investigate ongoing spoofing and layering activity in HPQ shares. He warns these manipulative tactics continue to distort market sentiment and harm small-cap companies. Mr. Tourillon urges CIRO to act quickly to protect investors and restore confidence.
DEEP DIVE
Ongoing Patterns, New Brokers Involved
Last month, I submitted a formal request to the Canadian Investment Regulatory Organization (CIRO) asking for a review of what appeared to be spoofing and layering activity in HPQ Silicon’s trading. Since then, I’ve continued to monitor our stock—and what we’re now seeing is not only ongoing but growing in scale and severity.
We’ve identified new instances of suspicious trading behavior on August 1, August 5, and August 6. Large pre-market sell orders were placed across multiple price levels—again at 7:00 AM, again cancelled before the open.
These weren’t isolated cases.
This time, the activity didn’t just originate from one broker. While Morgan Stanley (House 53) remains prominent, we’ve also observed similar behavior from Brokers 80, 7, and 124. In one case, orders were even placed well above market value—an unusual and irregular signal that strongly suggests an attempt to artificially influence sentiment on both the upside and the downside.
These are the classic signs of spoofing and layering: placing orders to create a false impression of liquidity, only to cancel them before they can be executed. These tactics distort the price discovery process and exploit the structure of thinly traded small-cap markets like the TSX Venture Exchange.
Impact on HPQ and Small-Cap Companies
For a company like HPQ, this has real consequences.
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.
We are an R&D-driven firm that has spent years developing advanced technologies in fumed silica, hydrogen, and high-performance battery materials. Our progress is public, measurable, and verifiable. Yet despite that, the trading patterns in our stock continue to diverge from fundamentals in ways that suggest market signals are being deliberately manipulated.
Small-cap companies do not have the luxury of ignoring this kind of behavior.
It weakens investor trust, undermines valuations, and impairs our ability to raise growth capital. When trading is dominated by algorithmic activity reacting to false signals, or by market participants exploiting opaque rules through dark pools or aggressive order-cancel tactics, the entire foundation of price discovery is compromised.
In my latest letter to CIRO, I have once again asked for formal investigation into these repeated patterns, with additional screenshots, time-stamped data, and a broader request that includes more brokers and more days of activity. We also observed a coordinated trade cluster on August 6 that bears the hallmarks of artificial market depth inflation. And while CIRO has assured us that the matter will be investigated confidentially, I must say—waiting in silence while visible manipulation continues is not sustainable.
Clarifying the PyroGenesis Factor
I want to address a point that has been raised regarding the recent sale of HPQ shares by PyroGenesis.
Their Q2 financials confirmed the liquidation of 10,836,500 HPQ shares between May 20 and June 30, 2025, with my own review suggesting that the remainder of their holdings was likely sold by August 5. While this activity did have a temporary impact on our share price, it was driven by PyroGenesis’ own liquidity needs, as disclosed in their MD&A, and not by any loss of confidence in HPQ or its projects.
It’s important to look at the broader picture. During the period of abnormal trading, over 60.3 million HPQ shares changed hands. Even if PyroGenesis sold all 17.6 million of its shares during that time, it would account for only about 28% of total volume.
That leaves more than 70% of the trading unconnected to PyroGenesis—activity that, based on our evidence, bears the hallmarks of illegal manipulation. While both events may have influenced our stock price, only one—market manipulation—is unlawful and undermines the integrity of our markets. That is where regulatory attention must be focused.
Respect for Process, But Urgency is Critical
I respect the process CIRO follows.
As I understand, when complaints are submitted, they are referred to CIRO’s Trading Review and Analysis (TR&A) team for preliminary evaluation. If the TR&A finds sufficient evidence of a potential rule breach, cases are escalated to enforcement or forwarded to other regulatory bodies.
I appreciate the care and confidentiality that governs this process, especially given the importance of ensuring fairness for all parties. However, I must emphasize that in this case, the urgency is real.
The trading behavior we’ve documented is happening in plain sight.
The rules being violated—namely those prohibiting manipulative and deceptive trading practices—are clear. Delays in enforcement only deepen the damage. Each day that spoofing and layering go unchecked in our stock chips away at shareholder confidence, and more broadly, public confidence in the integrity of Canada’s venture markets.
You can read the full follow-up letter and view the supporting documentation [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.
