Would it be just one rogue order filled? Not sure how after-hours tracking works, but I assume that it won't have a very deep order book, so it would be relatively easy to manipulate it. Given that BRK.A has the highest share price among any stocks, that order book would be even smaller.
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[ 2.5 ms ] story [ 32.9 ms ] threadLikely one person that placed a market order
One does not simply place a market order during after hours trading...
It could have been a deliberate limit order to avoid a margin call by raising the mark-to-market value of an account.