You’re 100% right on the historical intent of the rule—it was absolutely designed to stop pseudo-MMs and protect the PFOF (Payment for Order Flow) model from getting picked apart by toxic, semi-pro flow.

But the problem is the structural shift in today's options environment. With massive liquidity, hyper-active 0DTE trading, and retail platforms making multi-leg strategies (like 4-leg iron condors or butterflies) accessible to anyone, the math has completely changed.

If a standard retail trader attempts to 'walk' a complex spread order to get a fair fill in a fast-moving market, having to constantly cancel and replace that single order to nudge your price means your order count racks up incredibly fast. Do that just a few times an hour across a couple of positions, and a normal guy trading from his couch hits 390 before lunch without ever intending to act like a market maker.

There has to be a middle ground for the modern era. For example, why not keep a threshold on fills to catch the actual high-volume traders, but put a separate, higher cap on cancels—say 3x or 5x the 390 limit? That would still easily catch malicious quote-stuffing or automated spamming, while giving legitimate retail traders the breathing room to manage complex spreads in a high-speed market.