61 Susan Winter, CFA, manages a small-cap fund and a growth fund. Both funds hold Artificial Intelligence Limited (AIL), an illiquid stock that is suitable for both funds. After a significant increase in AIL's stock price, she decides to sell all AIL stock from the funds despite several analysts expecting further price increases of artificial intelligence stocks. Before selling AIL stock from both funds, to protect the interest of investors in the funds, she trades AIL back and forth between the two funds. This results in large and growing volumes observed by other market participants. Winter then sells all AIL stock from both funds.

Did Winter violate the Standard relating to market manipulation?