Battea Q1 2023 Client Newsletter

Antitrust Settlement Funds with Imminent Claims Filing Deadlines

Settlement:	Settlement Fund:	Claims Filing Deadline:	Class Period:
AUSSIE BENCHMARK FIXING (BBSW) SETTLEMENT	$185,875,000	January 16, 2023	January 1, 2003 through August 16, 2016
SIBOR (SOR) SETTLEMENT	$155,458,000	January 20, 2023	January 1, 2007 through December 31, 2011
EUROYEN-BASED DERIVATIVES SETTLEMENT (PARTIAL)	$22,500,000	April 28, 2023	January 1, 2006 through June 30, 2011
EUROPEAN GOVERNMENT BOND ANTITRUST SETTLEMENT	$13,000,000	June 26, 2023	January 1, 2007 through December 31, 2012
CBOT WHEAT FUTURES SETTLEMENT	$18,000,000	July 10, 2023	February 1, 2015 through May 15, 2015

BBSW (AUSSIE BANK BILL SWAP RATE) SETTLEMENT:
- ELIGIBLE CLASS: All persons who purchased, acquired, sold, held, traded or otherwise had any interest in BBSW-Based Derivatives at any time from January 1, 2003 through August 16, 2016 (the “Class Period”), inclusive.
- ELIGIBLE INSTRUMENTS: “BBSW-Based Derivatives” means any financial derivative instrument that is based or priced in whole or in part in any way on the Bank Bill Swap Rate (“BBSW”) or in any way includes BBSW as a component of price (whether priced, benchmarked and/or settled by BBSW), entered into by a U.S. person, or by a person from or through a location within the U.S., including, but not limited to: (i) Australian dollar foreign exchange (“FX”) derivatives, including Australian dollar FX forwards (also known as “outright forwards” or “outrights”), Australian dollar FX swaps (also known as “currency swaps”), Australian dollar currency options, Australian dollar futures contracts (such as the Chicago Mercantile Exchange (“CME”) Australian dollar futures contract) and options on such futures contracts; (ii) BBSW-based interest rate derivatives, including interest rate swaps, swaptions, forward rate agreements (“FRAs”), exchange-traded deliverable swap futures and options on those futures, 90-day bank accepted bill (“BAB”) futures and options on those futures, and other over-the-counter (“OTC”) contracts or publicly traded vehicles that reference BBSW; (iii) Australian dollar cross-currency swaps; and (iv) any other financial derivative instrument or transaction based in whole or in part on BBSW, or that in any way incorporates BBSW as a component of price, or is alleged by Representative Plaintiffs in this Action to be based in whole or in part on BBSW, or to in any way incorporate BBSW as a component of price. For the avoidance of doubt, BBSW-Based Derivatives do not include: (i) any BBSW-based deposits or loans, including floating rate notes, deposit-taking facilities, and commercial loans that are priced or call for payments due, in whole or in part, based on BBSW, including Australian dollar deposits and loans (“BBSW-Based Deposits or Loans”); or (ii) any negotiable certificates of deposit (“NCDs”) and bank accepted bills (“BABs”) issued and accepted by Prime Banks (collectively, “Prime Bank Bills”) or Prime Bank eligible securities. “Prime Banks” means the banks designated by AFMA as prime banks during the Settlement Class Period.

SIBOR SOR SETTLEMENT:
- ELIGIBLE CLASS: Subject to certain exceptions, the proposed Settlement Class consists of all persons (including both natural persons and entities) who purchased, sold, held, traded, or otherwise had any interest in SIBOR- and/or SOR-Based Derivatives during the period from January 1, 2007 through December 31, 2011 (the “Class Period”).
- ELIGIBLE INSTRUMENTS: “SIBOR- and/or SOR-Based Derivatives” means (i) a SIBOR- and/or SOR-based interest rate swap entered into by a U.S. Person, or by a Person from or through a location within the U.S.; (ii) an option on a SIBOR- and/or a SOR-based interest rate swap (“swaption”) entered into by a U.S. Person, or by a Person from or through a location within the U.S.; (iii) a Singapore Dollar currency forward agreement entered into by a U.S. Person, or by a Person from or through a location within the U.S.; (iv) a SIBOR- and/or SOR-based forward rate agreement entered into by a U.S. Person, or by a Person from or through a location within the U.S; and/or (v) a SIBOR- and/or SOR-based foreign exchange swap entered into by a U.S. Person, or by a Person from or through a location within the U.S. For the avoidance of doubt, all references herein to transactions of any kind entered into by a Person “through a location within the U.S.” include transactions that by operation of a forum selection clause or other contractual provision provide for jurisdiction in any state or federal court within the U.S. in the event of a dispute. *NOTE: Battea is requesting ALL SIBOR/SOR based derivatives trading data. Battea will file and track the claim to ensure you will receive your maximum recovery possible.

EUROYEN-BASED DERIVATIVES SETTLEMENT (PARTIAL):
- ELIGIBLE CLASS: All persons who purchased, sold, held, traded, or otherwise had any interest in any Euroyen-Based Derivatives during the class period, who were either domiciled in the United States or its territories or, if domiciled outside the United States or its territories, transacted Yen Libor/Tibor Products in the United States between January 1, 2006 and June 30, 2011 (the “Class Period”).
- ELIGIBLE INSTRUMENTS: “Euroyen-Based Derivatives” means (i) a Euroyen TIBOR futures contract on the Chicago Mercantile Exchange (“CME”); (ii) a Euroyen TIBOR futures contract on the Tokyo Financial Exchange, Inc. (“TFX”), Singapore Exchange (“SGX”), or London International Financial Futures and Options Exchange (“LIFFE”) entered into by a U.S. Person, or by a Person from or through a location within the U.S.; (iii) a Japanese Yen currency futures contract on the CME; (iv) a Yen-LIBOR- and/or Euroyen TIBOR-based interest rate swap entered into by a U.S. Person, or by
  a Person from or through a location within the U.S.; (v) an option on a Yen-LIBOR and/or a Euroyen TIBOR-based interest rate swap (“swaption”) entered into by a U.S. Person, or by a Person from or through a location within the U.S.; (vi) a Japanese Yen currency forward agreement entered into by a U.S. Person, or by a Person from or through a location within the U.S.; and/or (vii) a Yen-LIBOR- and/or Euroyen TIBOR-based forward rate agreement entered into by a U.S. Person, or by a Person from or through a location within the U.S.

EUROPEAN GOVERNMENT BOND ANTITRUST SETTLEMENT:
- ELIGIBLE CLASS: All persons and entities who or which purchased or sold one or more European Government Bond(s) in the United States directly from a Defendant or a direct or indirect parent, subsidiary, affiliate, or division of a Defendant, or any of their alleged co-conspirators, from January 1, 2007, through December 31, 2012 (the “Class Period”).
- ELIGIBLE INSTRUMENTS: “European Government Bonds” means euro-denominated sovereign debt or bonds issued by European governments (e.g., Austria, Belgium, Cyprus, Estonia, Finland, France, Germany, Greece, Ireland, Italy, Luxembourg, Malta, the Netherlands, Portugal, Slovakia, Slovenia, and Spain).

CHICAGO BOARD OF TRADE WHEAT FUTURES OR OPTIONS (“CBOT”) ANTITRUST SETTLEMENT:
- ELIGIBLE CLASS: All persons or entities that transacted in “CBOT” wheat futures or options during the period from February 1, 2015 through May 15, 2015 (the “Class Period”).
- ELIGIBLE INSTRUMENTS: “CBOT Wheat Futures or Options” means wheat futures and options contracts that trade on the Chicago Board of Trade (“CBOT”).

Battea Q1 2023 Client Newsletter:

Equities Settlement Funds with Imminent Claims Filing Deadlines

Settlement:	Settlement Fund:	Claims Filing Deadline:	Class Period:
MCKESSON CORP	$141,000,000	May 10, 2023	October 24, 2013 through October 27, 2016
MOHAWK INDUSTRIES INC.	$60,000,000	July 5, 2023	April 28, 2017 through July 25, 2019
IMMUNOMEDICS INC.	$40,000,000	June 8, 2023	February 9, 2018 through January 17, 2019
UNITED STATES STEEL CORP.	$40,000,000	March 1, 2023	January 27, 2016 through April 25, 2017
CREDIT SUISSE GROUP ADR	$32,500,000	April 6, 2023	October 29, 2020 through March 31, 2021
CONDUENT INC.	$32,000,000	May 19, 2023	February 21, 2018 through November 6, 2018
OMEGA HEALTHCARE INVESTORS, INC.	$30,750,000	March 24, 2023	February 8, 2017 through October 31, 2017
LYFT INC.	$25,000,000	May 22, 2023	March 28, 2019 through August 19, 2019

MCKESSON CORP.:
- ELIGIBLE CLASS: All persons that purchased or acquired McKesson common stock between October 24, 2013 and October 27, 2016 (the “Class Period”), inclusive.
- ELIGIBLE INSTRUMENTS: McKesson common stock.

MOHAWK INDUSTRIES INC.:
- ELIGIBLE CLASS: All persons or entities who purchased or otherwise acquired publicly traded common stock of Mohawk Industries, Inc. (“Mohawk”) during the period from April 28, 2017 through July 25, 2019 (the “Class Period”), inclusive.
- ELIGIBLE INSTRUMENTS: Mohawk common stock.

IMMUNOMEDICS INC.:
- ELIGIBLE CLASS: All persons who purchased or otherwise acquired the common stock of Immunomedics between February 9, 2018 and January 17, 2019 (the “Class Period”), inclusive, and were damaged thereby.
- ELIGIBLE INSTRUMENTS: Immunomedics, Inc. common stock.

U.S. STEEL CORP.:
- ELIGIBLE CLASS: All persons other than Defendants who purchased or otherwise acquired United States Steel Corporation securities between January 27, 2016 and April 25, 2017 (the “Class Period”), inclusive, or otherwise acquired shares pursuant to and/or traceable to the August 15, 2016 Secondary Public Offering (“SPO” or “Secondary Public Offering”).
- ELIGIBLE INSTRUMENTS: U.S. Steel common stock.

CREDIT SUISSE GROUP ADR:
- ELIGIBLE CLASS: All persons who purchased or otherwise acquired Credit Suisse American Depositary Receipts between October 29, 2020 and March 31, 2021 (the “Class Period”), inclusive.
- ELIGIBLE INSTRUMENTS: Credit Suisse American Depositary Receipts.

CONDUENT INC.:
- ELIGIBLE CLASS: All persons who purchased Conduent common stock on the open market on a United States stock exchange between February 21, 2018, and November 6, 2018 (the “Class Period”), inclusive, and who were damaged thereby.
- ELIGIBLE INSTRUMENTS: Conduent Inc. common stock.

OMEGA HEALTHCARE INVESTORS, INC.:
- ELIGIBLE CLASS: All persons and/or entities who purchased or otherwise acquired Omega securities from February 8, 2017 through October 31, 2017 (the “Class Period”), both dates inclusive.
- ELIGIBLE INSTRUMENTS: Omega Healthcare Investors, Inc. securities.

LYFT INC.:
- ELIGIBLE CLASS: All persons and entities who, during the period from March 28, 2019, through August 19, 2010, inclusive (the “Class Period”), purchased or otherwise acquired the common stock of Lyft issued and traceable to the IPO Registration Statement.
- ELIGIBLE INSTRUMENTS: Lyft Inc. common stock.

Battea Q1 2023 Client Newsletter:

Cryptocurrency Settlement Funds

* NOTE: Hundreds of millions of dollars have already settled in various cryptocurrency cases, including, but not limited to, Tezos Tokens ICO, Block.one, GTV Media Group (Coin Offering) . We also expect a number of other cryptocurrency cases currently in litigation to settle, with more expected litigation on the horizon. Due to the complexity of the financial instruments involved, Battea is requesting that you send ALL cryptocurrency trading data, ensuring you will receive your maximum recovery possible.

Pending Settlement:	Settlement Fund:	Claims Filing Deadline:	Class Period:
TRON FOUNDATION	TBD	TBD	August 24, 2017 through Present
BPS FINANCIAL LIMITED	TBD	TBD	October 1, 2019 through January 31, 2022
SAFEMOON LLC	TBD	TBD	March 8, 2021 through June 29, 2022
UNIVERSAL NAVIGATION INC.	TBD	TBD	April 5, 2021 through April 4, 2022
SOLANA LABS INC. TOKENS	TBD	TBD	March 24, 2020 through July 1, 2022
TERRA TOKENS	TBD	TBD	March 17, 2021 through May 25, 2022
CELSIUS TOKENS	TBD	TBD	February 9, 2018 through July 13, 2022
VOYAGER TOKENS	TBD	TBD	January 1, 2020 through November 9, 2022
COMPOUND DAO TOKENS	TBD	TBD	December 8, 2021 through December 8, 2022

TRON FOUNDATION:
- ELIGIBLE CLASS: All persons who purchased Tron Tokens, (“TRX”) tokens, which were first sold on or about August 24, 2017, in a domestic transaction and were injured thereby. The Class Period is thus August 24, 2017, through the present.
- ELIGIBLE INSTRUMENTS: TRX tokens.

BPS FINANCIAL LIMITED:
- ELIGIBLE CLASS: All holders and merchants of “BPS” from October 1, 2019 through January 31, 2022.
- ELIGIBLE INSTRUMENTS: BPS Tokens.

SAFEMOON LLC:
- ELIGIBLE CLASS: All persons who, during the Class Period, March 8, 2021 through June 29, 2022, purchased SafeMoon’s (“SAFEMOON”) Tokens and were subsequently damaged thereby.
- ELIGIBLE INSTRUMENTS: SAFEMOON Tokens.

UNIVERSAL NAVIGATION INC.:
- ELIGIBLE CLASS: All persons who purchased any Tokens on the Exchange during the Class Period (April 5, 2021 through April 4, 2022) and were harmed thereby are referred to herein as the “Class.”
- ELIGIBLE INSTRUMENTS: Uniswap has offered and sold unregistered securities, including EthereumMax, Bezoge Earth, Matrix Samurai, Alphawolf Finance, Rocket Bunny, and BoomBaby.io (collectively, the “Tokens”).

SOLANA LABS INC.:
- ELIGIBLE CLASS: All persons investors who purchased Solana tokens which are unregistered securities, issued and sold by Defendants beginning on March 24, 2020, through July 1, 2022.
- ELIGIBLE INSTRUMENTS: Solana Tokens.

TERRA TOKENS:
- ELIGIBLE CLASS: All persons and entities, other than Defendants and their affiliates, who purchased Terra Tokens between March 17, 2021, and May 25, 2022, inclusive (“Class Period”).
- ELIGIBLE INSTRUMENTS: Terra Tokens.

CELSIUS TOKENS:
- ELIGIBLE CLASS: All persons who purchased Celsius Financial Products (“CEL Tokens”) by way of a Celsius Earn Rewards Account, the Company’s so-called native “CEL Tokens,” and/or the Celsius Loans from February 9, 2018 to July 13, 2022.
- ELIGIBLE INSTRUMENTS: Celsius Financial Products.

VOYAGER TOKENS:
- ELIGIBLE CLASS: All persons who purchased unregistered securities in the form of: (1) cryptocurrency interest-earning accounts referred to as Voyager’s “Earn Program”; and (2) Voyager Tokens issued and sold by Defendants and Voyager (“VGX”).
- ELIGIBLE INSTRUMENTS: Voyager Tokens.

COMPOUND DAO TOKENS:
- ELIGIBLE CLASS: All people who purchased or obtained Compound Dao Tokens (“COMP”) on or after December 8, 2021. Excluded from the class are Defendants; corporate officers, members of the boards of directors, and senior executives of Defendants; members of their immediate families and their legal representatives, heirs, successors or assigns; and any entity in which Defendants have or had a controlling interest.
- ELIGIBLE INSTRUMENTS: COMP Tokens.

Battea Q1 2023 Client Newsletter:

International Litigation Updates

Petrobras “Lava Jato” Litigation

The Stichting Petrobras Compensation Foundation (SPCF) litigation represents investors damaged from the “Lava Jato” bribery scandal who traded the relevant Petrobras securities (excluding the US traded ADRs and bonds covered by the US settlement). The SPCF estimates damages for the equity class of investors alone exceeds $15 billion. The SPCF claim was filed pursuant to Dutch law that separates merits and damages into different and sequential litigations. Oral hearings on the merits concluded in January 2023. The Court indicated that it would issue a ruling in July 2023. The Court also requested that the parties (SPCF and Petrobras defendants) inform the Court if any progress toward a voluntary settlement is made prior to July, to assist with the Court’s scheduling as it relates to rendering the final ruling.

In the event of an expected favorable merits ruling, and no prior settlement reached, SPCF will immediately seek to file individual damages claims on behalf of all registered. ISAF, SPCF’s administrator, has generally closed registration for new participants. Closing the registration process was deemed necessary by SPCF and ISAF to provide ample time for the next possible phase of litigation or early resolution. However, ISAF has agreed that Battea clients who have not yet registered will be considered for inclusion on a case-by-case basis.

SPCF urges any impacted investor that has not yet registered to contact ISAF as soon as possible. For more information, contact your Battea Account Manager.

Danske Bank Money Laundering Scandal

Several investor group claims were filed against Danske Bank after revelations of its role in one of the largest money laundering scandals in history. The court selected lead group in Denmark’s high court is currently engaged in discovery issues while the other investor groups are generally stayed pending rulings on the lead action. However, Danske Bank has recently asked the court for a ruling that certain investor groups pay a cost deposit and answer questions raised in its first reply statement to the Writ. Counsel for investors is considering the appropriate response.

Relatedly, on December 13, 2022, Danske Bank pled guilty and agreed to a $2.06 billion fine in a case from the United States Department of Justice (DOJ). Many stakeholders view the DOJ announcement as a helpful development in the ongoing securities litigation in Denmark. Importantly, Danske Bank has agreed with the DOJ that the bank will not make any communications, including in ongoing or future Court proceedings, that contradict the admission of guilt.

Volkswagen “Dieselgate” Scandal

The Volkswagen (VW) shareholder litigation proceeding in Germany is playing out on two parallel tracks. The Lower Court is considering the standing of individual plaintiffs, including the authority to pursue a damage claim against VW and validation of relevant transaction data. The result of the proceedings in the Lower Court determines whether an individual claimant is dismissed or stayed. If the claimant is stayed, its claim is validated and allowed into the Higher Court collective action, the “KapMuG” complex.

The Higher Court is currently adjudicating the broader VW investor case for the KapMuG. On March 6, 2023, the Higher Court rendered decisions on certain aspects of the case, including how the Higher Court is considering the legal and moral duties VW management and Board owed to investors/claimants. The decision had few conclusions and largely contemplated how extensive the discovery and evidence phase of the trial will be. The Higher Court indicated that the evidentiary phase of the trial could stretch out over the next few years and suggested to the parties that a negotiated voluntary settlement would be a beneficial option to consider.

Battea Q1 2023 Client Newsletter:

New Virtual Offerings

New Battea.com Website

We are excited to announce the launch of our new website! We redesigned our website and improved the navigation for users to better access our securities class and collective action news, case spotlights, actionable insight, and new multimedia offerings, including “The Battea Knowledge Center”. Tour the new Battea.com today.

Battea’s “International Litigation Spotlight”

Battea’s “International Litigation Spotlight” kicked off in January 2023. David Abel, External Counsel to Battea Class Action Services, hosted the first two installments with Kyle Nolan, Associate, at Maples Group, focusing on how Ireland is a gateway to Europe that might soon see changes in shareholder activity, and Brett Spiegel and Cameron Myers, Principal Lawyers, at Phi Finney McDonald, highlighting the important implications Australia may have on shareholder litigation in 2023 and beyond. Learn More.

Battea Q1 2023 Client Newsletter:

Partner Spotlight

“Friends of Battea & WTax Event” at InvestOps USA 2023

In March, Battea and WTax were honored to host the “Friends of Battea & WTax Event”. The event was hosted in conjunction with the InvestOps USA 2023 Conference, March 27-29, in Orlando, FL. More than 200 leaders from all over the globe joined to strategize, network, and learn more of the leading innovations in the investment operations space.

In 2022, WTax and Battea Class Action Services partnered to improve withholding tax and securities class action claim success for investors. WTax currently works with over 5,000 funds globally to provide withholding tax recovery services. By utilizing WTax’s services, investors can reduce the withholding tax rate down to as low as 0% on certain investments, and on average, a WTax client will experience a fund performance increase of 5 basis points per year. More information on their services can be found at wtax.co.

Reminder: The main ingredient in a successful filing is the data – in this case your data!

If you have any questions about how you can ensure that we have all of your eligible transactional data, please contact your customer service representative or call at (203) 987-4949.