In a manipulation case (Article 155) based on misleading misstatements or omissions, the causal link between the defendant's misconduct and the plaintiff's harm is provided by the manipulation's effect on the market. In a deception case (Article 20) based on the defendant's affirmative misstatements, reliance must be pleaded and proved by the plaintiff. Additionally, investors cannot easily detect distortions of implicit information, such as wash sales and matched orders. Hence, the concept of manipulation (Article 155) cannot be replaced by Article 20. In this research, manipulation is treated as a medium of communication between manipulators and markets. In other words, as long as the signal the manipulator sends is truthful information, I claim that stock manipulation should be allowed by law.