All persons or entities that engaged in U.S.-based transactions in financial instruments that were priced, benchmarked, and/or settled based on SIBOR and/or SOR at any time from at least January 1, 2007 through December 31, 2011. Excluded from the Class are Defendants and their employees, agents, affiliates, parents, subsidiaries and co-conspirators, whether or not named in this complaint, and the United States government.

SIBOR/SOR based derivatives: All financial instruments that were priced, benchmarked, and/or settled based on SIBOR and/or SOR and that were transacted in U.S. based transactions, including over the counter instruments such as interest rate swaps, forward rate agreements, and foreign exchange swaps and forwards.

The complaint alleges that Defendants agreed, combined and conspired to rig SIBOR and SOR to fix the prices of SIBOR- and SOR-based derivatives in violation of the Sherman Act, 15 U.S.C. § 1, et seq., the Racketeer Influenced and Corrupt Organizations Act (“RICO”), 18 U.S.C. § 1961 et seq., and the common law. Specifically, the defendants (1) knowingly submitted (or caused to be submitted) SIBOR and SOR quotes that were false, misleading, or inaccurate because they were manipulative, based in whole or in part on impermissible and illegitimate factors, such as the rate that would financially benefit Defendants’ SIBOR based derivatives positions and/or the SIBOR-based derivatives positions of their coconspirators; (2) Defendants implicitly represented that their SIBOR submissions were a reliable and truthful assessment of, and only of, each Defendant’s competitive market borrowing costs; (3) Defendants used secret, collusive trades in the swap market to manipulate SOR and the prices of SOR-based derivatives.

Antitrust class action about Defendants’ unlawful conspiracy to increase the profitability of their derivatives trading in the United State through the manipulation of two related benchmark rates—the Singapore Interbank Offered Rate (“SIBOR”) and the Singapore Swap Offer Rate (“SOR”). At the same time that they were manipulating SIBOR and SOR, Defendants traded derivatives incorporating these tainted rates with investors located in the United States.