Plaintiffs allege that the Defendants colluded to manipulate “London Gold Market Fix,” a global benchmark reference rate used in the price often agreed to be used in advance by buyers and sellers of gold. Throughout the Class Period (as defined below), The Bank of Nova Scotia,
Barclays, Deutsche Bank, HSBC, and Société Générale (the “Fixing Bank Defendants”) met
privately twice each London business day for what is aptly known as the London Gold Market
Fixing (hereafter the “London Gold Fixing” or “Fixing”). The Fixing produces a benchmark
rate for gold, a price often agreed to be used in advance by buyers and sellers of gold. Plaintiffs assert that defendants colluded to manipulate the London Gold Market Fix rate to ensure the rate moved in the direction that they wished to ensure maximum profitability, rather than a fair auction as intended.
All persons or entities who during the period from January 1, 2004 through June 30, 2013, either (A) sold any physical gold or financial or derivative instrument in which gold is the underlying reference asset, including, but not limited to, those who sold (i) gold bullion, gold bullion coins, gold bars, gold ingots or any form of physical gold, (ii) gold futures contracts in transactions conducted in whole or in part on COMEX or any other exchange operated in the United States, (iii) shares in gold exchange-traded funds (“ETFs”), (iv) gold call options in transactions Case 1:14-md-02548-VEC Document 187 Filed 12/09/16 Page 3 of 84conducted over-the-counter or in whole or in part on COMEX or any other exchange operated in the United States; (v) gold spot, gold forwards or gold swaps over-the-counter; or (B) bought gold put options in transactions conducted over-the- counter or in whole or in part on COMEX or on any other exchange operated in the United States.
Defendants (the “Fixing Bank Defendants”)
- Bank of Nova Scotia
- Deutsche Bank
- Société Générale
- Deutsche Bank
Partial Settlements: $60,000,000
Filing Deadline: Not yet established
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