This is pretty stupid. So let's say I put in orders half of the size of Corsica's biggest orders - then would my spoofing technique be okay. No? A quarter of the size? No? An eight of the size? No? A sixteenth of the size? ...
If they are so concerned about spoofing, why don't they just require orders to stay active in the book for a few seconds. Then you enforce no spoofing by the exchange rules themselves. But no, let's waste time trying to figure out "intent" of all live orders and also waste taxpayer money to take people to court. What a joke. All because the HFTs have the regulators in their back pockets.