Plaintiffs allege that Defendants manipulated Euribor and the prices of Euribor Products. For example, panel banks that made daily Euribor submissions to Thomson Reuters, such as Barclays, HSBC and Deutsche Bank, allegedly falsely reported their borrowing costs, in order to financially benefit their Euribor Products positions. Defendants also requested that other Defendants make false Euribor submissions on their behalf, to benefit their Euribor Products positions. Plaintiffs further allege that Defendants conspired to fix prices of Euribor Products in the over-the-counter market to financially benefit their own Euribor Products positions. In addition to coordinating Euribor submissions and agreeing on where to price Euribor Products, in order to allegedly manipulate Euribor and Euribor Products during the Class Period, Defendants allegedly engaged in “pushing cash,” transmitted false bids and offers, used derivative traders as submitters, and rigged bids and offers for Euribor Products.
All Persons that purchased, sold, held, traded, or otherwise had any interest in any Euribor Products between June 1, 2005 and March 31, 2011, (“Class Period”), who were either domiciled in the United States or its territories or, if domiciled outside the United States or its territories, transacted Euribor Products in the United States or its territories during the Class Period, including, but not limited to, all Persons who traded CME Euro currency futures contracts, all Persons who transacted in NYSE LIFFE Euribor futures and options from a location within the United States, and all Persons who traded any other Euribor Product from a location within the United States.
- Barclays plc
- Barclays Bank plc
- Barclays Capital Inc. (collectively, “Barclays”)
- HSBC Holdings plc
- HSBC Bank plc (collectively, “HSBC”)
- Deutsche Bank AG
- DB Group Services (UK) Ltd. (collectively, “Deutsche Bank”)
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