All persons or entities who, within the Class Period, directly entered into fixed-for floating, floating-for-fixed, or floating-for-floating interest rate swaps with the Dealer Defendants, or their respective affiliates, in the United States and its territories.

IRS is a type of financial derivative. It is an agreement between two parties to trade interest-rate cash flows on a specific amount of money for a fixed period of time. In the most common type of swap — often referred to as a “plain vanilla” swap — one counterparty pays the other a fixed interest rate in exchange for receiving a floating interest rate. The floating rate is often tied to an industry benchmark such as the LIBOR. The counterparty paying a fixed rate is typically referred to as the “buyer,” and the counterparty making payments at the floating rate is known as the “seller.” The value of the contract to each side moves (in opposite directions) depending on changes in interest rates.

Conspiracy among major interest rate swaps (“IRS”) dealers (“Dealer Defendants”) to boycott Plaintiffs in order to undermine increased competition in the IRS market and thereby maintain the Dealer Defendants’ massive profits.

According to the complaint, from at least January 2009 through December 2014, the Dealer Defendants conspired to prevent buy side investors from trading IRS on modern all-to-all anonymous electronic trading platforms that provide more transparent and competitive trading options. They also conspired to prevent buy side investors from trading with each other, thus ensuring that a dealer bank remains on one side of every trade.

The complaint alleges that absent a conspiracy, it would have been in the individual interest of many different market participants — including IDBs, clearinghouses, and SEFs — to offer an all-to all trading platform solutions to the buy side. Instead, because of Defendants’ conspiracy, the SEFs that have tried to offer such platforms have been put out of business, and SEFs like Tradeweb that replicate the structure of the OTC market by offering the buy side only a dealer to-client RFQ have prospered. Without Defendants’ collusion, offerings such as those by Javelin, TeraExchange, and TrueEX would have generated large new revenue streams through increased volume and market share.