10/09/2023 ($105 Société Générale)
07/31/2019 ($182.5 Million Citi and JP Morgan Chase)
08/01/2018 ($309 Million Barclays, HSBC and Deutsche)
13-cv-2811 U.S. District Court for the Southern District of New York
June 1, 2005 – March 31, 2011
TOTAL SETTLEMENT FUND:
Barclays, HSBC, Deutsche, Citi, JP Morgan Chase, Société Générale, Credit Agricole
DISMISSED NON-SETTLING DEFENDANTS:
UBS, RBS, ICAP, and Rabobank (Appeal Pending)
All Persons that purchased, sold, held, traded, or otherwise had any interest in any Euribor Products, 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 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.
All interest rate swaps, swaptions, forward rate agreements, futures, options, structured products, and other instruments related in any way to Euribor, also including FX futures, forwards, swaps and options.
Plaintiffs allege that, during the Class Period, Defendants Barclays plc, Barclays Bank plc, Barclays Capital Inc., Citigroup, Inc., Citibank, N.A., Coöperatieve Rabobank U.A. (f/k/a Coöperatieve Centrale Raiffeisen-Boerenleenbank B.A.), Crédit Agricole S.A., Crédit Agricole CIB, Deutsche Bank AG, DB Group Services (UK) Ltd., HSBC Holdings plc, HSBC Bank plc, ICAP plc, ICAP Europe Limited, J.P. Morgan Chase & Co., JPMorgan Chase Bank, N.A., The Royal Bank of Scotland plc, Société Générale SA, and UBS AG (collectively, “Defendants”) agreed, combined, and conspired to rig Euribor and fix the prices of Euribor Products. Defendants allegedly did so by using several means of manipulation. For example, panel banks that made daily Euribor submissions to Thomson Reuters allegedly falsely reported their costs of borrowing 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 continuously conspired to fix the 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 effectuate their manipulations of Euribor and Euribor Products during the Class Period, Defendants engaged in “pushing cash,” transmitted false bids and offers, used derivative traders as submitters, and rigged bids and offers for Euribor Products.
Plaintiffs have asserted legal claims under various theories, including federal antitrust law, the Commodity Exchange Act (“CEA”), the Racketeering Influenced and Corrupt Organizations Act (“RICO”), and common law.
Barclays, HSBC, and Deutsche Bank have consistently and vigorously denied Plaintiffs’ allegations.
If you transacted in Euribor Products1 between June 1, 2005 and March 31, 2011, inclusive (“Class Period”), then your rights will be affected by a pending class action settlement, and you may be entitled to a portion of the settlement fund. The purpose of this Notice is to inform you of your rights in connection with the proposed settlement with Settling Defendant Société Générale in the action titled Sullivan, et al. v. Barclays plc, et al., No. 13-cv-2811 (PKC) (S.D.N.Y.). The settlement with Société Générale (the “Settlement”) is not a settlement with any other Defendant and thus is not dispositive of any of Plaintiffs’ claims against other Defendants.
The Settlement has been proposed in a class action lawsuit concerning the alleged manipulation of the Euro Interbank Offered Rate (“Euribor”) and the prices of Euribor Products during the Class Period. The Settlement provides a total of $105 million to pay claims from persons who transacted in Euribor Products during the Class Period. If you qualify, you may potentially receive benefits from the Settlement if you (a) previously submitted a Proof of Claim and Release form (“Claim Form”) in connection with prior settlements in this Action or (b) submit a Claim Form by the deadline set forth below. You can also choose to exclude yourself from the Settlement, or object to the Settlement.
Improper conduct relating to the setting of the Euro Interbank Offered Rate (Euribor), a global reference rate used to benchmark, price and settle over $200 trillion of financial products.
Settlement Fund: $491.5 million
Deutsche Bank: $170,000,000
Credit Agricole: $105,000,000
Barclays plc: $94,000,000
HSBC Holdings: $45,000,000