There is more to this to diagnose a pump and dump. According to these criterias, the internet bubble of 2000 would have been recognized as a pump and dump too.
There are quite a few people who hold exactly that opinion. For instance, check out Alex Berenson's The Number: How the Drive for Quarterly Earnings Corrupted Wall Street and Corporate America, or read any "alternative" financial blog, and this line of reasoning might start to make at least some sense.