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”).

“CBOT Wheat Futures or Options” means wheat futures and options contracts that trade on the Chicago Board of Trade (“CBOT”).

Plaintiffs allege that Defendants manipulated the prices of CBOT Wheat Futures or Options by signaling false demand for Soft Red Winter Wheat. According to Plaintiffs, Lansing established CBOT Wheat Futures or Options position that would financially benefit from Defendants’ signal of demand. After establishing the position, Lansing allegedly acquired wheat shipping certificates, cancelled those certificates, and demanded load out of the underlying SRW, which Plaintiffs allege signaled a false demand for SRW consumption that caused the prices of CBOT Wheat Futures or Options to become artificial. Plaintiffs also allege that Cascade enhanced the visibility of this signal by its publication of an article that Plaintiffs allege highlighted Lansing’s alleged market behavior, although the article never identified Lansing by name. Plaintiffs allege that Lansing traders knew that cancelling these wheat shipping certificates would signal demand to the market and cause CBOT Wheat Futures or Options prices to be artificial. Plaintiffs further allege this signal of demand was false because Lansing did not cancel the wheat shipping certificates to satisfy a true demand for SRW, but instead cancelled the certificates to benefit its CBOT Wheat Futures or Options trading positions, at the expense of Class Members’ positions.

All persons or entities that transacted in CBOT Wheat Futures or Options during the period from February 1, 2015 through May 15, 2015.