All persons in Canada who, within the class period, entered into an instrument traded in the foreign exchange market, either directly or indirectly through an intermediary, and/or purchased or otherwise participated in an investment or equity fund, mutual fund, hedge fund, pension fund or any other investment vehicle that entered into an instrument traded in the foreign exchange market.

Spot, Forwards, Swaps, Options, FX Futures, Options on Futures, as well as limited investment vehicles which may have entered into FX transactions indirectly.

It is alleged that the Defendants conspired with each other to fix prices in the FX Market. It is alleged in the claim that the Defendants communicated directly with each other to coordinate their: (i) fixing of spot prices; (ii) controlling and manipulating FX benchmark rates; and (iii) exchanging key confidential customer information in an effort to trigger client stop loss orders and limit orders.

It is alleged that the Defendants conspired with each other to fix prices in the FX Market. It is alleged in the claim that the Defendants communicated directly with each other to coordinate their: (i) fixing of spot prices; (ii) controlling and manipulating FX benchmark rates; and (iii) exchanging key confidential customer information in an effort to trigger client stop loss orders and limit orders. The Defendants alleged conspiracy affected dozens of currency pairs, including the U.S. and Canadian dollar (USD/CAD) currency pair, which is one of the worlds highest volume trading currency pairs. Due to the importance of spot prices, it is alleged that the Defendants alleged conspiracy impacted all manner of FX instruments, including those trading both over-the-counter and on exchanges.