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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posited the liquidity crisis had created a situation where LIBOR at times no longer represents the level at which banks extend loans to others; specifically, the analysts concluded LIBOR may understate actual interbank lending costs by 20-30bp [basis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].

To the contrary, Defendantsin the debt-instrument context, the borrowers: the worlds most important number now tweets daily, May 21, 2009, available at last accessed on April 28, 2012. Metz, How Far Can Screens Go in Distinguishing Explicit from Tacit Collusion? Defendant West deutsche Immobilien Bank AG is a German company headquartered in Mainz and wholly owned subsidiary of Defendant West LB.35. Morgan Futures, Inc.; (v) HSBC Securities (USA); (vi) Barclays Capital Inc.; (vii) UBS Securities LLC; (viii) RBS Securities Inc.; (ix) Deutsche Bank Securities; and (x) Citigroup Global Markets Inc.44.

17 Carrick Mollenkamp and Mark Whitehouse, Study Casts Doubt on Key Rate --- WSJAnalysis Suggests Banks May Have Reported Flawed Interest Data for Libor, The Wall Street Journal , May 29, 2008. New Evidence from the Libor Setting, CPI Antitrust Chronicle , March 201They also affected the LIBOR-based derivative market in products like Eurodollar futures. During the Class Period, Defendants BAC, Credit Suisse, JPMorgan Chase, HSBC, Barclays, Lloyds, HBOS, West LB, RBS, UBS, Deutsche Bank, Citibank, Royal Bank of Canada, Rabobank, BTMU and Norinchukin were members of the BBAs USD-LIBOR panel. In addition to the above entities participation in selling LIBOR-based financial instruments to Plaintiffs during the Class Period, investigations regarding Defendants manipulation of Yen-LIBOR (detailed below) have revealed that securities-dealer subsidiaries of Yen-LIBOR panel members, including Defendant UBS, participated in manipulating Yen-LIBOR during the Class Period.

For example, market participants commonly set the interest rate on floating-rate notes as a spread against LIBOR ( e.g. Its funds traded on-exchange based products tied to LIBOR such as Eurodollar futures and were harmed as a consequence of Defendants unlawful conduct.21.

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.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.Moreover, numerous pending government investigationsboth domestically and abroad, including by the DOJ, the Commodity Futures Trading Commission (CFTC), and the SECconcerning potential LIBOR manipulation could yield information from Defendants internal records or personnel that bears significantly on Plaintiffs claims. because of the difficulty in proving that banks reported borrowing costs for LIBOR3at one rate and obtained funding at another.Indeed, as one news report observed in detailing U. regulators ongoing investigation, [i]nternal bank emails may prove to be key evidence . 2 Plaintiffs thus believe further evidentiary support for their allegations will come to light after a reasonable opportunity for discovery. This case arises from the manipulation of LIBOR for the U. dollar (USD-LIBOR or simply LIBOR) 3 - the reference point for determining interest rates for trillions of dollars in financial instruments - by a cadre of prominent financial institutions.

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