I don't think I understand Cramer's argument. Is he asserting the new worst-case valuation is disingenuous because it's a "nice" number like 10?
Does that mean he wouldn't be saying anything about it if it were 11 instead? That seems like just as subjective an assessment as the one he's currently making. A seemingly "random" looking number can be just as arbitrarily chosen as a neat looking one.
It wouldn't surprise me to know analysts like to slightly round up or down a valuation target to hit a neat number like 10. But that seems like human nature to me, not a lack of integrity or critical analysis. I don't think this is a very critical heuristic to use...