All Persons or entities who entered into, received or made payments on, settled, terminated, transacted in, or held an ISDAfix Instrument during the Settlement Class Period. Excluded from the Settlement Class are Defendants and their employees, affiliates, parents, subsidiaries, and co-conspirators, should any exist, whether or not named in the Amended Complaint, and the United States Government, and all of the Released Parties provided, however, that Investment Vehicles shall not be excluded from the definition of the Settlement Class.

“ISDAfix Instrument” means (i) any and all interest rate derivatives, including but not limited to any swaps, swap spreads, swap futures, variance swaps, volatility swaps, range accrual swaps, constant maturity swaps, constant maturity swap options, digital options, cash-settled swaptions, physically-settled swaptions, swapnote futures, cash-settled swap futures, steepeners, flatteners, inverse floaters, snowballs, interest rate-linked structured notes, and digital and callable range accrual notes where denominated in USD or related to USD interest rates, and (ii) any financial instruments, products, or transactions related in any way to any USD ISDAfix Benchmark Rates, including but not limited to any instruments, products, or transactions that reference USD ISDAfix Benchmark Rates and any instruments, products, or transactions relevant to the determination or calculation of USD ISDAfix Benchmark Rates.

The lawsuit alleges that the Defendants engaged in anticompetitive acts that affected the market for ISDAfix Instruments in violation of Section 1 of the Sherman Act, 15 U.S.C. § 1. The lawsuit also alleges that the Defendants were unjustly enriched under common law and breached ISDA Master Agreements by their anticompetitive acts. The lawsuit was brought by, and on behalf of, certain Persons who transacted in ISDAfix Instruments. The Defendants deny doing anything wrong.

The Class Plaintiffs allege, among other things, that the Defendants colluded to manipulate USD “ISDAfix,” a global benchmark reference rate used in the interest rate derivatives market. The Class Plaintiffs allege the Defendants are 14 banks that dominate the market for interest rate derivatives as well as inter-dealer broker ICAP, which administered the ISDAfix-setting process during the Settlement Class Period. In general, the Class Plaintiffs allege the Defendants rigged the ISDAfix rates to secure supra-competitive profits on their derivative positions.