Ken Wolfe who posts on Real Money from time to time has a "Dumper Play" strategy where he screens for stocks that are down 20% in pre-market on big volume. He then looks for the stocks to start to come in a few minutes close to the open.
If you follow the levels of short selling, and notice that over the past few weeks pros have been lightening up while the public is loading up, this may be a valid strategy for a while. Especially if we start to move up over the next few weeks.
But I would be leery of doing it on an overnight basis without some sort of edge or knowledge beyond the fact that it is down, since it can just as easily gap down 2 days in a row.
I have thought about both, but between MSO and MO, I would think MO may be a sensible play. MSO is done without Martha, unless they start to sell assemble yourself prison jumpsuits. But MO still has all of the world tobacco markets plus a fat dividend to boot. Just my thoughts, not saying take either since I am just a 6 year old girl playing on daddy's computer.