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Except as alleged in this Complaint, neither Plaintiffs nor other members of the public have access to the underlying facts relating to Defendants improper activities.Rather, that information lies exclusively within the possession and control of Defendants and other insiders, which prevents Plaintiffs from further detailing Defendants misconduct. As detailed later in the Complaint, those analyses indicate Defendants manipulated LIBOR as of at least August 8, 2007 and continued their manipulation through at least May 17, 2010Plaintiffs claims are made on information and belief (except as to allegations specifically pertaining to Plaintiffs and their counsel, which are made on personal knowledge) based on the investigation conducted by and under the supervision of Plaintiffs counsel. This action arises from Defendants unlawful and intentional misreporting and manipulation of as well as their combination, agreement and conspiracy to fix LIBOR rates and to restrain trade in the market for LIBOR-based derivatives during the respective Class 1 Plaintiffs have delineated the Class Period based on currently available information, including the independent analysis performed by consulting experts Plaintiffs have retained, as well as analyses undertaken by experts retained by other plaintiffs in these coordinated proceedings.Defendant s perpetrated a scheme to depress LIBOR for two primary reasons.First, well aware that the interest rate a bank pays (or expects to pay) on its debt is widely, if not universally, viewed as embodying the markets assessment of the risk associated with the bank, Defendants understated their borrowing costs to the British Bankers Association (BBA) (thereby suppressing LIBOR) to portray themselves as economically healthier than they actually wereof particular importance given investors trepidation in light of the widespread market turmoil of the past few years.For example, during the Class Period, nine of the sixteen banks that served on the U. dollar also served on the Japanese yen, Swiss franc and Euro LIBOR panels. 12 It is a requirement of membership of a LIBOR contributor panel that the bank is regulated and authorized to trade on the London money market. 1367 because those claims are so related to the federal claim that they form part of the same case or controversy, and under 28 U. The range of funds includes various types of securities, money market, and derivative funds, as well as general and specialized investment funds.10 Similarly, thirteen banks participated on both the dollar and yen LIBOR panels 11 and eleven banks participated on both the U. As the BBA recently told Bloomberg: As all contributor banks are regulated, they are responsible to their regulators, rather than us. As the primary benchmark for short term interest rates globally, 14 LIBOR has occupied (and continues to occupy) a crucial role in the operation of financial markets. This Court also has jurisdiction over the state law claims under 28 U. Metzler manages assets totaling approximately 47 billion and is based in Frankfurt, Germany.
Inaddition to floating-rate notes, whose interest rates are specifically set as a variable amount over LIBOR, market participants use LIBOR as the starting point for negotiating rates of return on short-term fixed-rate instruments, such as fixed-rate notes maturing in one year or less. Plaintiffs allegations that Defendants suppressed LIBOR are supported by (i) Defendants powerful incentives to mask their true borrowing costs and to reap unjustified revenues by setting artificially low interest rates on LIBOR-based financial instruments that investors purchased; (ii) an independent analysis by other plaintiffs consulting experts, comparing LIBOR panel banks daily individual quotes with the banks probability of default, as measured by Kamakura Risk Information Services, as well as by Plaintiffs consulting experts conducting analyses of the spread between LIBOR as reported and the Federal Reserve Eurodollar Deposit Rate; (iii) publicly available economic analyses, by prominent academics and other commentators, of LIBORs behavior during the Class Period compared with other wellaccepted measures of Defendants borrowing costs, as well as the notable tendency of Defendants daily submitted LIBOR quotes to bunch near the bottom quartile of the collection of reported rates used to determine LIBOR; and (iv) revelations in connection with the numerous domestic and foreign governmental investigations into potential manipulation of USD-LIBOR and LIBOR for other currencies, most prominently Yen-LIBOR and Euroyen TIBOR. Defendants each had substantial financial incentives to suppress LIBOR.Indeed, in an April 10, 2008 report, analysts at Defendant Citigroup Global Markets Inc.posited the liquidity crisis had created a situation where LIBOR at times no longer represents the level at which banks extend loans to others; specifically, the analysts concluded LIBOR may understate actual interbank lending costs by 20-30bp [basis points].12 Those banks are Bank of Tokyo, Barclays, Citibank, Credit Suisse, Deutsche Bank, HSBC, JPMorgan Chase, Lloyds, Rabobank, RBS, and UBS. 14 Accordingly, it is well-established among market participants that, as The Wall Street Journal has observed, confidence in LIBOR matters, because the rate system plays a vital role in the economy. Plaintiff 303030 Trading LLC (303030) is an Illinois limited liability corporation with its principal place of business in Lake County, Illinois. (JPMorgan Chase) is a Delaware financial holding company headquartered in New York, New York. Defendant HSBC Holdings plc (HSBC) is a British public limited company headquartered in London, England.17 Moreover, given the vast universe of financial instruments LIBOR impacts, even a small manipulation of the rate could potentially distort capital allocations all over the world. Throughout the Class Period, Defendants betrayed investors confidence in LIBOR, as these financial institutions conspired to, and did, manipulate LIBOR by underreporting to the BBA the actual interest rates at which the Defendant banks expected they could borrow unsecured funds in the London interbank market i.e. The BBA then relied on the false information Defendants providedto set LIBOR. 303030 traded on-exchange based products tied to LIBOR such as Eurodollar futures and were harmed as a consequence of Defendants unlawful conduct.25. Defendant HSBC Bank plc is a United Kingdom public limited company headquartered in London, England and a wholly owned subsidiary o Defendant Lloyds Banking Group plc (Lloyds) is a British public limited company headquartered in London, England.