All Persons who purchased, sold, held, traded, or otherwise had any interest in any Euroyen-Based Derivatives 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 Yen Libor/Tibor Products in the United States.

Yen Libor and/or Tibor IRS, swaptions, Tibor exchange traded futures, FX yen forwards, swaps, options and futures, options on futures.

Plaintiffs allege that each Defendant, between January 1, 2006 through June 30, 2011, inclusive, manipulated or aided and abetted the manipulation of Yen-LIBOR, Euroyen TIBOR, and the prices of Euroyen-Based Derivatives.

Plaintiffs allege that each Defendant, between January 1, 2006 through June 30, 2011, inclusive, manipulated or aided and abetted the manipulation of Yen-LIBOR, Euroyen TIBOR, and the prices of Euroyen-Based Derivatives. Defendants allegedly did so by using several means of manipulation. For example, panel banks that made the daily Yen-LIBOR and/or Euroyen TIBOR submissions to the British Bankers Association and Japanese Bankers Association (the Contributor Bank Defendants), such as the Citi Defendants and HSBC Defendants, allegedly falsely reported their cost of borrowing in order to financially benefit their Euroyen-Based Derivatives positions. Contributor Bank Defendants also requested that other Contributor Bank Defendants make false Yen-LIBOR and Euroyen TIBOR submissions on their behalf to benefit their Euroyen-Based Derivatives positions.