It is a tricky one as it has a decieving immediate and substantial break higher after the Secondary Test, you could label this move above the AR in Phase B as Upthrust Action (as a Sign of Strength) but it does make it difficult to define the Range. You should be confident though as it appears correct to my eye, I would have set the horizontal upper Supply line at the level of the AR as for me this takes priority, and then use the misalignment of the PS to construct a trending Range, but I only do this because that's what makes sense to me, you should do what makes sense to you, and to reiterate Jakos words "to understand what's happening here, what's taking place" is the ultimate priority. The PS aligns closely to the AR which gives some validation to the structure, and the Secondary Test in Phase B could be forseen as a potential Spring in the Final Test in Phase C until it is disproven with a fall back below the midline of the Range. The response to the potential Spring in Phase C is a clear Sign of Strength and is followed by a clear close above the highest point in the Range, a Major Sign of Strength, which gives some validation to the Spring theory until proven otherwise. When forming a structure, and this is in regards to structure only not VSA analysis, there can only be one Spring, and it will take price above the midline in a Sign of Strength, above the previous highest point in the Range in a Major Sign of Strength and will usually go through Backing up Action as a test of the breakout before moving higher, however if momentum is strong price may simply move into Markup in Phase E without Backing Up.
The Accumulation or Distribution always starts with Stopping Action, this is the reason we look for a Change of Character from a Downtrend into a Sideways trend, just to clarify the Sideways trend begins before the break of the Downtrend as the breaking of the downtrend is as a result of the Change of Character in Phase A, so price will probably break the downtrend in Phase B or D.
The downtrend being broken is one of the Wyckoff Buying Tests, I copied a link to Stockcharts below, it is a great study reference for this material supplied by Bruce Fraser. http://stockcharts.com/school/doku.php?id=chart_school:market_analysis:the_wyckoff_method
Wyckoff Buying Tests for Accumulation
Downside price objective accomplished – P&F chart
Preliminary support, selling climax, secondary test - Bar and P&F charts
Activity bullish (volume increases on rallies and diminishes during reactions) – Bar chart
Downward stride broken (that is, supply line or downtrend line penetrated) - Bar or P&F chart
Higher lows - Bar or P&F chart
Higher highs - Bar or P&F chart
Stock stronger than the market (that is, stock more responsive on rallies and more resistant to reactions than the market index) - Bar chart
Base forming (horizontal price line) – Bar or P&F chart
Estimated upside profit potential is at least three times the loss if the initial stop-loss were hit – P&F and bar charts
Cheers, great to see someone else having a go at the Structural work, I find it fascinating
(20min delay)