All persons or entities who during the Class Period: (i) sold gold bullion or gold bullion coins; (ii) sold gold futures contracts traded on COMEX or other exchanges operated in the United States; (iii) sold shares in Gold ETFs; (iv) sold gold call options traded on COMEX or other exchanges operated in the United States; (v) bought gold put options traded on COMEX or other exchanges operated in the United States; (vi) sold over-the-counter gold spot or forward transactions or gold call options; or (vii) bought over the-counter gold put options.

Physical, derivative, and futures, including products such as any physical gold, gold bars, ingots, gold coins, gold futures contracts on the COMEX or other exchanges in the US, shares in gold ETF’s, Gold OTC spot, forwards, swaps and options.

The complaint alleges that throughout the Class Period The Bank of Nova Scotia, Barclays, Deutsche Bank, HSBC, and Société Générale (the “Fixing Bank Defendants”) met privately twice each London business day for what is aptly known as the London Gold Market Fixing (hereafter the “London Gold Fixing” or “Fixing”).  The Fixing produces a benchmark rate for gold, a price often agreed to be used in advance by buyers and sellers of gold (the “Fix  price”).

Specifically, the complaint alleges that Defendants’ manipulative tactics included, among other things, “front running” (trading in own positions in advance of customer orders to take advantage of the market’s resulting move when the client’s orders are placed), “spoofing” (placing large orders that are never executed), “wash sales” (placing large orders that are executed then quickly reversed), and “jamming” (using such techniques to trigger a stop-loss order or to avoid a bank’s having to pay on an option or similar contracts).