Plaintiffs allege that, from January 1, 2008, through November 30, 2014, inclusive (the “Settlement Class Period”), Defendants conspired to drive down the price of platinum and palladium during two daily and allegedly secret and unregulated meetings, a morning call (the “AM Fixing”) and afternoon call (the “PM Fixing”) (collectively, the “Fixing”). According to Plaintiffs, the AM and PM Fixings were intended to set global benchmark price per ounce of platinum and palladium (the “Fix price”) based on supply and demand fundamentals stemming from a supposedly competitive platinum and palladium auction among the Fixing members. In 2004, the Defendants established The London Platinum and Palladium Fixing Company Ltd. (“LPPFC”) to operate as the vehicle for the AM and PM Fixings. Defendants allegedly capitalized on the lack of regulatory oversight and the private nature of the AM and PM Fixings to facilitate Defendants’ alleged agreement to manipulate and fix platinum and palladium prices and the prices of NYMEX Platinum and Palladium Investments during the Settlement Class Period. Plaintiffs allege that Defendants’ purported conduct harmed other market participants like Plaintiffs and the Settlement Class. For purposes of the notice, “NYMEX Platinum or Palladium Investments” means (i) platinum or palladium futures contracts traded on NYMEX, (ii) platinum or palladium call options traded on NYMEX, or (iii) platinum or palladium put options traded on NYMEX.
