UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF ILLINOIS 

MISH INTERNATIONAL 

MONETARY INC., on behalf of itself 

and all others similarly situated, 

Plaintiff, 

v. 

VEGA CAPITAL LONDON, LTD., 

Adrian Spires, Paul Commins, George 

Commins, Christopher Roase, Elliott 

Pickering, Aristos Demetriou, Connor 

Younger, James 

Biagioni, Henry Lunn, 

Paul Sutton, Matthew Rhys Thompson, 

and JOHN DOES 1-100, 

Defendants. 

 Case No. 1:20-cv-04577

 

SECOND AMENDED CLASS ACTION COMPLAINT 

Corrected Copy 

FILED UNDER SEAL 

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ERRATA

Paragraph Change

i-iii Insert table of contents.

passim Fixed internal citations.

35 Replaced “that Starmark is the principal of Vega” with “and has stated for years 

that the website is ‘currently in development’”

36 Changed

to 

219-220 Deleted “that day”

235 Changed “Anthony Gibson signed” to “It was also Commins’ partner, Anthony 

Gibson who signed”

239 Added 

239(g) Replaced with 

replaced with deleted 

239(f) Changed to 

240 Changed to 

changed to 

240-242 Changed to 

242 Changed Spires’ 

to 

Spires’ 

246 Added “typically” before “placed” and deleted “own” before “sub-account”

247 Changed “Vega enter trades on behalf of Vega, or” to “Vega to enter trades, or”

258 Changed “also” to “at times”

259(h) Added an open quote before 

Heading 3 Deleted “either”

295 Added “to” after “knowledge simultaneously”

305 Added an apostrophe after VTDs

311 Added “Defendant positions in the May Contract had an extremely 

high minute to minute correlation with other VTDs, e.g., .965 (Defendant Lunn); 

.965 (Defendant Roase); .960 (Defendant Demetriou) and .946 (Defendant 

Pickering)” after “21-25”

319-322 Changed “May 20th” to “April 20th”

329, 332 Changed “trading” to “positions”

359 Changed “.981” to “9.81”

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TABLE OF CONTENTS

SUMMARY OF ALLEGATIONS..........................................................................1 

JURISDICTION AND VENUE..............................................................................9 

PARTIES......................................................................................................11 

A. Plaintiff......................................................................................11 

B. Defendants..................................................................................12 

BACKGROUND.............................................................................................31 

A. Commodity Futures: How Futures Contract Trading Profits Or Losses

 Are Determined Using The May Contract As An Example..........................31 

B. The WTI Contract..........................................................................35 

C. Buying Pressure, Selling Pressure, Cumulative Net Sales And Cumulative 

 Selling Pressure.............................................................................38 

UNDERLYING ALLEGATIONS.........................................................................42 

A. The Abuse Of TAS Transactions To Manipulate Prices............................42 

B. Defendant Commins’ Background and Formation of a Group That Could 

 Execute a TAS Manipulation.............................................................45 

C. The Vega Defendants Manipulative Depression of May Contract Prices..........48 

D. The Vega Trading Defendants Combined, Conspired and Worked In 

 Concert For The Purpose of Depressing The Price Of The May 2020 

 WTI Crude Oil Futures Contract On April 20, 2020.................................51 

E. Net Cumulative Aggressive Sales Pressure.............................................64 

F. High Degree Of Communications Among Most Vega Defendants And 

 The Common Plan For Everyone To Be Short And Use Manipulative 

 “Ammo” At The End Of Trading........................................................71 

G. The ICE WTI Crude Oil Futures Contract Price Is Explicitly Determined

 By The Price Of The NYMEX WTI Crude Oil Futures Contract And 

 Numerous Vega Trading Defendants Profited On The ICE Due To 

 Artificially Depressing The May Contract Price On The NYMEX.................84 

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H. Vega Also Made Its Sales In An Aggressive Manner..............................87 

NEW ALLEGATIONS MADE PURSUANT TO THE ORDER....................................88

I. The Extensive Interconnections, And Formal Contract Among Vega, And 

 The Vega Trading Defendants.....................................................................88 

A. The Extensive Interconnections...........................................................88 

 1. The Profit Interests Of Defendants Vega And Spires In ...............88 

 2. The Formation of Vega...........................................................93 

 a. During 2015 And 2016, The United Kingdom Announces 

 And Implements Enhanced Prohibitions of Manipulation..........93 

 b. The Enhanced Protections Against Manipulation Created

 Greater Financial And Legal Risks For Firms Which Carried

 Accounts For Manipulators.............................................96 

 c. Vega’s Apparent Founder, Anthony Gibson, Is A Business

 Partner With Defendant Commins, Including In 

 ......................................................96 

 d. Vega’s High Turnover Of Four Owners In Three Years 

 Before Spires Become Sole Shareholder..............................98 

B. The Written Agreement Between And Among Vega, , And The 

 Vega Trading Defendants.................................................................98 

C. In Its “Market Facing” Agreement With GH Financials, Vega Expressly

 Agreed That It Was The Principal For Each Trade By A Vega Trading

 Defendant And That The Vega Trading Defendants Were Acting As Vega’s 

 “Agent” Or Otherwise Acting For Or On Behalf Of Vega..........................101 

 1. Long Before April 20, 2020, Defendants Vega And Spires Well 

 Knew That The VTDs Traded In Unison To Manipulate Prices.........104 

 2. The Vega Trading Defendants Engaged In Coordinated Trading 

 In WTI Crude Oil Futures Contracts A Month Prior To Engaging 

 In Substantially Similar But More Extreme Conduct On 

 April 20, 2020...................................................................109 

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 3. Based On The Vega Trading Defendants’ Activities On 

 March 19, 2020 And Other Reasons, Defendants Vega Capital 

 And Spires Knew That The Vega Trading Defendants Were 

 Engaged In Manipulative Trading And Affirmatively Took 

 Steps To Facilitate The Manipulation.........................................116 

 4. The VTDs Stalked Futures Contracts To Determine Those Most

 Vulnerable To Manipulation, And Then Blitz The Market By 

 Making Trades In Unison To Move Prices...................................120 

 5. Defendants Vega And Spires Actively Facilitated The April 20th

 Manipulation, Profited Therefrom, And Specifically Intended That

 The Trades Which Vega Was Making In The May Contract Would

 Manipulatively Depress May Contract Prices................................121 

 6. Defendant ......................................................127 

 7. Defendant Paul Sutton..........................................................129 

CLASS ALLEGATIONS.................................................................................132

INJURY TO PLAINTIFF AND CLASS MEMEBERS...............................................135 

AS AND FOR A FIRST CLAIM AGAINST ALL DEFENDANTS................................135 

AS AND FOR A SECOND CLAIM AGAINST ALL DEFENDANTS............................137

AS ANF FOR A THIRD CLAIM AGAINST ALL DEFENDANTS...............................140 

AS AND FOR A FOURTH CLAIM AGAINST ALL DEFENDANTS............................141 

AS AND FOR A FIFTH CLAIM AGAINST ALL DEFENDANTS................................142 

AS AND FOR A SIXTH CLAIM AGAINST ALL DEFENDANTS.............................144 

AS AND FOR A SEVENTH CLAIM AGAINST ALL DEFENDANTS..........................145 

AS AND FOR AN EIGHTH CLAIM AGAINST ALL DEFENDANTS.........................147 

PRAYER FOR RELIEF...................................................................................148 

DEMAND FOR JURY TRIAL...........................................................................150 

 

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Pursuant to this Court’s Order (dated March 31, 2022, Dkt. No. 117) 

(“Order”), Plaintiff complains1

 of Defendants (including in the new allegations 

made at paragraphs 37, 55, 57, 209-333 pursuant to the Order) as follows: 

SUMMARY OF ALLEGATIONS 

1. From at least as early as April 2020, the Vega Defendants2 combined, 

conspired, and agreed to depress on April 20, 2020 prices of the May 2020 West 

Texas Intermediate (“WTI”) Light Sweet Crude Oil futures contract (“May 

Contract”) which is traded on the Chicago Mercantile Exchange (“CME”) Globex 

platform. See ¶¶ 30-59 (specifying the Vega Defendants). 

2. Though not a necessary condition to the manipulation of a futures 

contract price, each of the following steps is a sufficient condition to manipulate a 

futures contract price. 

a. A combination of market participants exerts significant cumulative net 

selling pressure on a futures contract over a specific time period. Cumulative net 

selling pressure means a market participant’s sales of a futures contract minus their 

1

 Plaintiff complains based on personal knowledge as to ¶29 and information and belief as to all 

other paragraphs. Plaintiffs’ information includes CME records, Vega records produced to the 

CME, news articles, the materials referenced and alleged in this Complaint, and the investigation 

of counsel. 

2

 As used in this complaint, the “Vega Defendants” means VEGA CAPITAL LONDON, LTD., 

Adrian Spires, Paul Commins, George Commins, Christopher Roase, Elliott Pickering, Aristos 

Demetriou, Connor Younger, James Biagioni, Henry Lunn, Paul 

Sutton, Matthew Rhys Thompson, and Vega Defendant John Does 1-4. 

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purchases of such futures contract during a specified time period. See ¶ 129 below. 

Here, Defendants agreed to and did abuse the Trade at Settlement (“TAS”) feature 

of the May Contract to build up their cumulative net selling pressure on the May 

Contract.3

 See ¶129. 

b. A market participant uses their sales in a futures contract as 

manipulative “ammo”. See ¶ 103. “Ammo” has been recognized by the United 

States CFTC and the United Kingdom Financial Control Authority (“FCA”) as a 

term used by manipulators. See ¶¶104-105; and fn. 5-6. The term “ammo” signifies 

possession of the ability to make a quantity of transactions in a manner in which 

the transactions will depress or inflate futures contract prices. See ¶¶ 103-105. 

Here, Defendants Thompson and Lunn 

 

3

 As recently stated by Commodity Futures Trading Commission (“CFTC”) Commissioner Dan 

Berkovitz on November 24, 2020: “The potential for TAS trading to artificially affect the 

settlement price of a contract is well known; indeed, the CFTC has brought two enforcement 

cases based on the use of TAS to manipulate the price of futures contracts.” See 

https://www.cftc.gov/PressRoom/SpeechesTestimony/berkovitzstatement112320a. 

Commissioner Berkovitz also expressed his view that the CFTC should look into the TAS 

trading activity in its investigation of the precipitous drop and rebound of WTI oil trading prices 

on April 20-21. 

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Elliot Pickering

 

 

[Emphasis added]. Based upon the Vega Trading Defendants’ actual conduct, 

Plaintiff has good grounds to believe and does allege that Defendants agreed to and 

did use their sales as manipulative “ammo” to depress May Contract prices from 

approximately 12 pm on April 20 through the TAS settlement of the May Contract 

by 1:30 pm on that day. See ¶145(c)-(e) below. 

c. A market participant is responsible for an increasing share of the net 

sales made by the entire market, including at times when the market participant 

already has exerted substantial cumulative net selling pressure on such futures 

contract. Here, after Defendants had built up substantial net selling pressure on the 

May Contract, Defendants engaged in a frenzy of selling which greatly increased 

their sales per minute and caused their percentage of the entire market’s sales to 

exceed 30% in this worldwide market. See ¶ 145. 

d. A market participant builds up a significant cumulative net 

“aggressive” sales pressure on a futures contract over a specified time. See ¶ 146-

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164 (alleging the CME’s definition of “aggressive” transactions and Defendants’ 

buildup of their significant cumulative net aggressive sales pressure). 

3. Although any one of the above steps would have sufficed to 

manipulatively depress prices, Defendants agreed to and did engage in all of the 

foregoing types of manipulative steps and thereby greatly depressed May Contract 

prices on April 20. 

4. Regarding Defendants’ combination and agreement to depress prices, 

the manipulation of an entire market is something that persons can better 

accomplish working in a combination and pursuant to an agreement rather than 

individually. Yet even the broadest agreements and best manipulations entail risks. 

Here, the Vega Trading Defendants each committed their capital to Vega to 

guarantee one another’s losses. Such Defendants effectively acted as coguarantors to Vega of one another’s financial outcomes. This is exactly the type of 

agreement which would facilitate joint efforts to manipulate prices as well as 

Vega’s involvement with such efforts. 

5. Also indicating Defendants’ agreement, Defendant Paul Commins, in 

his own words, all but two of the other Vega Trading Defendants. 

Further indicative of an agreement, the five Vega Trading Defendants who build 

up the largest May Contract short positions, did so in a manner that is extremely 

highly correlated on a minute-by-minute basis with one another as well as with 

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Defendant Paul Commins’ buildup of his May Contract short position. See ¶¶142-

43. This is extremely unlikely to happen by independent decision making or freak 

occurrence. It is highly consistent with a very carefully executed agreement to 

build cumulative net selling pressure on the market in a manner which will succeed 

in depressing prices. 

6. Confirming that these multiple high correlations among many 

Defendants’ May Contract short positions did not result from chance, there was a 

high degree of communications among Vega Trading Defendants on April 20. This 

includes communications in which they coordinate trades (which helps to explain 

the high degree of correlation in the growth of their positions). They also 

communicated to track what one another was doing and make sure they were going 

short May Contracts and long TAS contracts to build up net selling pressure on the 

May Contract. See below. 

7. Likewise, when Defendants exulted in the successful outcome of their 

manipulation after the close of trading in the May Contract on April 20, Defendant 

Lunn stated 

 See ¶ 179 below. In fact, the Vega Trading Defendants 

had used the foregoing four means of manipulation (alleged at ¶2 a-d) to 

overwhelm and “blitz” through the limited buying pressure in the May Contract. 

As the Vega Defendants’ cumulative net selling pressure and manipulative ammo 

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sales reached their highest levels, Vega caused the May Contract to experience alltime record price declines. See ¶¶136-137. 

8. Defendant George Commins Defendant Paul Commins 

and apparently resides at and definitely trades out of Defendant Paul Commins’ 

residence. , Defendant George Commins 

 See 

¶180 below. This further indicates coordination and joint conduct. 

9. GH Financial is a company located in this District and was the futures 

brokerage firm for Defendant Vega. On April 21, GH Financial informed Vega as 

follows: The trading by Vega in the May Contract on April 20 had set off multiple 

market alert alarms at GH Financial. Accordingly, the futures brokerage firm 

wanted to know whether the Vega persons doing the trading were acting together. 

Similarly, GH Financial wanted to know whether such persons appreciated 

exchange rules about market manipulation. And GH Financial asked numerous 

other questions about specific trades or traders, including relating to attempted 

manipulation. See ¶120 below. Soon after receiving Vega’s responses, GH 

Financial gave notice to Vega that it was dropping Vega as a customer. This notice 

was due to the events which occurred on April 20 and GH Financial’ s concerns 

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about the “risks” of continuing to do business with Defendant Vega and the Vega 

Trading Defendants. Id. 

10. As a result of Defendants extensive combination to overwhelm and 

depress the May Contract prices on April 20, Defendants proximately caused 

extremely artificial prices in the May Contract. 

11. Futures market “spreads” are the difference between the price of a 

futures contract expiring in one month and the price of a futures contract expiring 

in a different month 

12. Using futures contract spreads is a standard way to analyze whether 

the prices of a futures contract have deviated from supply and demand or are 

artificial in an economic sense of the term. The supply and demand for crude oil 

was substantially similar and the same on Friday April 17, Monday April 20, and 

Tuesday April 21. Based on a statistical analysis of the spread between the prices 

of the May Contract and the June WTI contract, and using a control period of 

January 2 until April 17, 2020, Plaintiff has good grounds to believe and does 

allege as follows. 

13. During trading on April 20, the spread between the May Contract

price and the June Contract price declined by an extreme amount. In fact, the 

amount of the decline was 138 standard deviations. A computer calculation of the 

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probability of this occurring in a competitive market untainted by manipulation 

returns a result of exactly zero. 

14. However, after 1:30 p.m. on April 20, Vega no longer had market

power over May Contract trading. The May June spread then snapped back and 

increased to (and above) the levels on which such spread had closed on April 17, 

2020. The statistical chance of this occurring in a competitive market is 

extraordinarily small. And the statistical chance that the May June spread, in a 

competitive market, would decline by so much on April 20 and then snapback so 

much on April 21 is even smaller. 

15. Because there were virtually no changes in supply and demand for 

crude oil between April 17 and April 21, much less dramatic decreases in the 

supply demand balance on April 20 followed by overwhelming increases in the 

supply demand balance on April 21, the fundamentals cannot explain what 

happened to prices here. However, Vega’s four types of manipulative conduct were 

present in the May Contract on April 20 until 1:30 pm and then were removed 

from the May Contract after 1:30 pm on April 20. 

16. Accordingly, the Vega Defendants’ blatantly manipulative “ammo”

selling and other manipulative steps alleged in ¶2 (a)-(d) are the proximate cause of 

the artificially depressed May Contract prices on April 20. 

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17. Plaintiff and members of the Class (as defined in ¶210) were directly 

injured by the Vega Defendants’ agreement and conduct. Among other things, 

Plaintiff and Class members were injured in that they sold May crude oil futures 

contracts to liquidate their long positions at artificially low prices. See ¶¶ 218-220 

below. 

JURISDICTION AND VENUE 

18. The CME Group’s global headquarters are located in this District at 

20 South Wacker Drive, Chicago, Illinois 60606. The May Contracts traded on the 

CME Group’s electronic trading platforms Globex and ClearPort. The CME 

Group’s electronic Globex trading platform is housed approximately thirty-five 

miles from the CME Group’s headquarters in Aurora, Illinois. All May Contract 

transactions, including Plaintiff’s and Defendants’ May Contract transactions, were 

entered and executed in this District. 

19. WTI crude oil is a “commodity” and is the “commodity underlying” 

the WTI crude oil futures contracts traded on the CME Globex, as those terms are 

defined and used in Sections 1a(4) and 22 of the CEA, 7 U.S.C. §§ 1a(4) and 

25(a)(1)(D), respectively. 

20. Defendants made use of the means and instrumentalities of 

transportation or communication in, or the instrumentalities of, interstate 

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commerce, or of the mails in connection with the unlawful acts and practices and 

courses of business alleged in this complaint. 

21. The Court has subject matter jurisdiction over this action pursuant to 7 

U.S.C. §25, Section 4 of the Clayton Act, 15 U.S.C. §15 and 28 U.S.C. §§1331 and 

1337. 

22. The Court has personal jurisdiction over Defendants pursuant to

Section 12 of the Clayton Act, 15 U.S.C. § 22. Defendants have minimum 

contacts with the United States, transacting business in this District, including by 

electronically placing trades in NYMEX WTI crude oil futures contracts on the 

Chicago Mercantile Exchange (“CME”) Globex and CME ClearPort trading 

platforms. 

23. General venue is proper in the Northern District of Illinois pursuant to 

7 U.S.C. §25(c), 15 U.S.C. §22 and 28 U.S.C. §1391(b), (c), and (d). 

24. The Court also has personal jurisdiction over Defendants and venue is 

proper pursuant to Section 22 of Commodity Exchange Act, 7 U.S.C. § 22. 

Defendants transact business in this judicial district and the CEA violations 

occurred in this District. 

25. Plaintiff’s and Defendants’ brokers are located in this District. See 

¶¶27, 67. The price manipulation occurred and the claims arose in this District. 

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Also, a substantial part of the events or omissions giving rise to the claims arose in 

this District. 

26.

27.

28. The ICE has a colocation data center in this District as well as in 

Mahwah, New Jersey and Basildon, United Kingdom. 

https://www.theice.com/connectivity-and-feeds/icecolocation

PARTIES 

A. Plaintiff 

29. Plaintiff Mish International Monetary, Inc. is a California corporation 

with its principal place of business in Menlo Park, California. On the afternoon of 

April 20, 2020, Plaintiff Mish sold, through his brokers located in this District, ten 

(10) May Contracts at negative prices in order to liquidate a long position in such 

contract. Plaintiff Mish incurred a net loss of approximately $92,490 in connection 

with the foregoing transactions executed in this District. Plaintiff sold at the 

artificially low May Contract prices registered which occurred in this District due 

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to Defendants’ manipulative impact on the trading executed and the order book 

maintained for May Contracts in this District. As alleged hereafter, Plaintiff is 

entitled to recover damages from Defendants, including actual damages, treble 

damages and other relief.

B. Defendants 

30. Defendant Vega Capital London, Ltd. (“Vega”) is a corporation 

organized and existing under the laws of the United Kingdom, incorporated on 

May 13, 2016, with a registered office in Essex, England and a principal place of 

business in London, England. Defendant Vega maintained a trading account with 

United States Futures Commissions Merchant (“FCM”) G.H. Financial LLC. See 

¶¶ 248, 263 below. 

31. In its trading account with GH Financial, Vega maintained multiple 

accounts and scores of sub-accounts. Part of these sub-accounts, those in 

contained the accounts of the Vega Trading Defendants, whose names are alleged 

in ¶39 below, except for Defendant whose account was in 

 But the Vega Trading Defendants did not have accounts with GH Financial and 

GH Financials’ only customer was Vega. Defendant Vega’s accounts included a 

master account 

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32. All of the Vega Trading Defendants entered their orders and made 

their trades (of which Plaintiff is so far aware in the May Contract) with GH 

Financial in the name of and through Defendant Vega.

33. On October 26, 2017, Defendant Vega registered with the FCA as an 

Appointed Representative of Starmark Investment Management Limited 

(“Starmark”). Defendant Vega terminated its registration with the FCA on August 

13, 2019. 

34. Currently, Vega is wholly owned by Defendant Adrian William Spires 

(see ¶34 below). As of Vega’s incorporation on May 13, 2016, Anthony Gibson 

was its sole shareholder. On July 1, 2017, Dean George Scott acquired all 

outstanding shares from Mr. Gibson. On September 26, 2017, Adrian Spires and 

Tommy Gaunt each acquired half of Mr. Scott’s shares, so that they co-owned the 

company equally. On October 23, 2019, after Defendant Vega had de-registered 

with the FCA, Defendant Spires acquired all of Mr. Gaunt’s shares.

35. According to its filings with the UK’s Companies House, Defendant 

Vega had zero employees in 2017, 3 employees in 2018 and 7 in 2019. Vega 

states on its website and has stated for years that the website is “currently in 

development”. 

36.

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37. Defendant Vega describes the individual trading defendants, whose 

names are alleged below, as However, the 

relationship between and among Vega, , and the Vega Trading Defendants is 

alleged in detail at ¶¶209-261 below. 

38. Defendant Adrian Spires is a natural person residing in the UK. 

Defendant Adrian Spires is Defendant Vega’s sole shareholder, sole owner and 

sole director. Prior to Vega’s de-registration with the FCA on August 13, 2019, 

Defendant Spires was registered with the FCA to provide financial services to the 

public as an appointed representative of both Starmark and Vega. Defendant Spires 

is still registered with the FCA as a representative of Starmark. The Vega Trading 

Defendants are Defendants Paul Commins, George Commins, Aristos Demetriou, 

Henry Lunn, Elliott Pickering, Christopher Roase, Paul Sutton, 

Matthew Thompson, Connor Younger, 

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and Michael Biagioni.

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39. Defendant Paul Commins is a natural person residing 

. Mr. Commins is registered with the FCA to provide financial 

services to the public as an appointed representative of Starmark. Defendant Paul 

Commins maintained an account with Defendant Vega. Defendant Paul Commins 

40. Defendant Paul Commins 

 In Defendant Paul 

Commins’ 

41. Defendant Paul Commins coordinated and worked with the other 

Vega Trading Defendants to depress the prices of the May Contract on April 20. 

(a) Defendant Paul Commins’ minute to minute pattern in his May Contract 

short position on April 20 is almost identical to and holds an extremely high 

correlation with the patterns in which Defendants Younger, Pickering, Demetriou, 

and Roase added to their May Contract short positions on April 20. See ¶¶45, 47, 

49, 51 (identifying Defendants Younger, Pickering, Demetriou and Roase) and 

¶143 (alleging the correlations). Such high correlations with one trader, much less 

many traders, have an extremely low likelihood of occurring by chance or from 

randomly independent trading decisions. 

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(b) Defendant Paul Commins exploited the TAS device to place selling 

pressure in the May Contract to net sell a total of May Contracts and avoid 

placing offsetting purchase pressure in the May Contract by purchasing TAS 

contracts on April 20. 

(c) Defendant Paul Commins sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

42. Defendant George Commins Defendant Paul Commins 

and also maintained an account with Defendant Vega. Defendant George Commins 

resides at, and traded on April 20, 2020 

 Defendant George Commins also maintained an account with Vega, is 

also registered with the FCA as an authorized representative of Starmark, and also 

is a member of 

43. Defendant George Commins worked with other Vega Defendants to 

depress the prices of the May Contract on April 20. Among other things, 

Defendant George Commins communicated with other Vega Defendants about the 

May Contract put selling pressure into the May Contract on April 20 by net selling 

May Contracts, and avoided putting offsetting buying pressure into the May 

Contract by net purchasing TAS contracts. Defendant George Commins sold a 

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large portion of his May Contracts in an aggressive manner and used his May 

Contracts as “ammo” during April 20, including during the last hour of trading. 

See ¶¶ 111, 164 below.

44. Defendant Connor Grant Younger is the son of a friend of Defendant 

Paul Commins. Defendant Younger is a natural person residing

 Defendant Younger also maintained an account with Vega, 

is also registered with the FCA as an authorized representative of Starmark, and 

also is a member of Defendant Paul Commins trading team.

45. (a) Defendant Connor Younger’s minute to the minute pattern of 

adding to his May Contract short position on April 20 is almost identical to and 

holds an extremely high correlation with the patterns in which Defendants Paul 

Commins, Pickering, Demetriou, and Roase added to their May Contract short 

positions on April 20. See ¶143 (identifying Defendants Paul Commins, Pickering, 

Demetriou and Roase) and ¶143 (alleging the .919 correlation to Defendant 

Commins’ trades). Such high correlations with one trader, much less many traders, 

have an extremely low likelihood of occurring by chance or from randomly 

independent trading decisions. 

(b) Defendant Younger exploited the TAS device to place selling pressure in 

the May Contract to net sell a total of May Contracts and avoid placing 

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offsetting purchase pressure in the May Contract by net purchasing TAS 

contracts on April 20. 

(c) Defendant Younger sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

46. Defendant Aristos Demetriou 

 Chris Roase 

 Defendant 

Demetriou has been a director of an entity called along 

with Defendant Commins and Defendant Pickering. Additionally, Defendant 

Demetriou co-owned a firm called with Defendant Paul 

Commins. Defendant Demetriou is a natural person residing 

 Defendant Demetriou also maintained an account with Vega, is also 

registered with the FCA as an authorized representative of Starmark, and also is a 

member of Defendant Paul Commins trading team.

47. (a) Defendant Demetriou’s minute to the minute pattern of adding to 

his May Contract short position on April 20 is almost identical to and holds an 

extremely high correlation with the patterns in which Defendants Paul Commins, 

Pickering, Younger, and Roase added to their May Contract short positions on 

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April 20. See ¶142 (identifying Defendants Paul Commins, Pickering, Younger 

and Roase) and ¶143 (alleging the .974 correlation to Defendant Commins’ trades). 

Such high correlations with one trader, much less many traders, have an extremely 

low likelihood of occurring by chance or from randomly independent trading 

decisions. 

(b) Defendant Demetriou exploited the TAS device to place selling pressure 

in the May Contract to sell a total of May Contracts and avoid placing 

offsetting purchase pressure in the May Contract by purchasing TAS 

contracts on April 20. 

(c) Defendant Demetriou sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

48. Defendant Elliott Edward Clark Pickering has been a director of an 

entity called ., along with Defendant Commins and 

Defendant Demetriou. Defendant Pickering is a natural person residing 

 Defendant Pickering also 

maintained an account with Vega, is also registered with the FCA as an authorized 

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representative of Starmark, and also is a member of Defendant Paul Commins 

trading team.

49. (a) Defendant Pickering’s minute to the minute pattern of adding to 

his May Contract short position on April 20 is almost identical to and holds an 

extremely high correlation with the patterns in which Defendants Paul Commins, 

Demetriou, Younger, and Roase added to their May Contract short positions on 

April 20. See ¶142 (identifying Defendants Paul Commins, Demetriou, Younger 

and Roase) and ¶143 (alleging the .940 correlation to Defendant Commins’ trades). 

Such high correlations with one trader, much less many traders, have an extremely 

low likelihood of occurring by chance or from randomly independent trading 

decisions. 

(b) Defendant Pickering exploited the TAS device to place selling pressure 

in the May Contract to net sell a total of May Contracts and avoid placing 

offsetting purchase pressure in the May Contract by net purchasing TAS 

contracts on April 20. 

(c) Defendant Pickering sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

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50. Defendant Christopher Roase 

 Defendant Commins Defendant Roase is a 

natural person residing 

. Defendant Roase also maintained an account 

with Vega, is also registered with the FCA as an authorized representative of 

Starmark, and also is a member of Defendant Paul Commins trading team.

51. (a) Defendant Roase’s minute to the minute pattern of adding to his 

May Contract short position on April 20 is almost identical to and holds an 

extremely high correlation with the patterns in which Defendants Paul Commins, 

Pickering, Younger, and Demetriou added to their May Contract short positions on 

April 20. See ¶142 (identifying Defendants Paul Commins, Pickering, Younger 

and Demetriou) and ¶143 (alleging the .976 correlation to Defendant Commins’ 

trades). Such high correlations with one trader, much less many traders, have an 

extremely low likelihood of occurring by chance or randomly independent trading 

decisions. 

(b) Defendant Roase exploited the TAS device to place selling pressure in 

the May Contract to sell a total of May Contracts and avoid placing 

offsetting purchase pressure in the May Contract by purchasing TAS 

contracts on April 20. 

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(c) Defendant Roase sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

52. Defendant Henry Lunn is a natural person residing 

Defendant Lunn also maintained an account with Vega, is also 

registered with the FCA as an authorized representative of Starmark, and also is a 

member of Defendant Paul Commins trading team. 

(a) Defendant Lunn’s minute to the minute pattern of adding to his May 

Contract short position on April 20 is almost identical to and holds an extremely 

high correlation with the patterns in which Defendants Paul Commins, Pickering, 

Younger, Roase, and Demetriou added to their May Contract short positions on 

April 20. See ¶142 (identifying Defendants Paul Commins, Pickering, Younger, 

Roase and Demetriou) and ¶143 (alleging the .946 correlation to Defendant 

Commins’ trades). Such high correlations with one trader, much less many traders, 

have an extremely low likelihood of occurring by chance or randomly independent 

trading decisions. 

(b) Defendant Lunn exploited the TAS device to place selling pressure in the 

May Contract by net selling May Contracts and avoid placing offsetting 

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purchase pressure in the May Contract by net purchasing TAS contracts on 

April 20. 

(c) Defendant Lunn sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading.

53. The five largest Vega traders accounted for 69% of the total Vega 

volume, and their minute by minute positions have extremely strong correlations 

(between 96.2% and 99.7%) with each other.

a. Younger’s sales of May Contracts on April 20 were the largest sales 

of any Vega defendant on April 20. Younger’s minute by minute 

positions in the May Contract had an extremely strong tendency 

(between .962 and .996) to increase as to the other largest Vega 

Traders on April 20 (Roase, Lunn, Demetriou, and Pickering).

b. Pickering’s sales of May Contracts on April 20 were the second 

largest sales of any Vega defendant on April 20. Pickering’s minute 

by minute positions in the May Contract had an extremely strong

tendency (between .973 and .996) to increase as to the other largest 

Vega Traders on April 20 (Roase, Lunn, Younger, and Demetriou).

c. Demetriou’s sales of May Contracts on April 20 were the third largest 

sales of any Vega defendant on April 20. Demetrious minute by 

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minute positions in the May Contract had an extremely strong 

tendency (between .977 and .997) to increase as to the other largest 

Vega Traders on April 20 (Roase, Lunn, Younger, and Pickering).

d. Roase’s sales of May Contracts on April 20 were the fifth largest sales 

of any Vega defendant on April 20. Roase’s minute by minute 

positions in the May Contract had an extremely strong tendency 

(between .962 and .997) to increase as to the other largest Vega 

Traders on April 20 (Demetriou, Lunn, Younger, and Pickering).

e. Lunn’s sales of May Contracts on April 20 were the fourth largest 

sales of any Vega defendant on April 20. Lunn’s minute by minute 

positions in the May Contract had an extremely strong tendency 

(between .981 and .993) to increase as to the other largest Vega 

Traders on April 20 (Roase, Demetriou, Younger, and Pickering).

54. Defendant Matthew Rhys Thompson is a natural person residing 

Defendant Thompson also maintained an account with Vega, is also 

registered with the FCA as an authorized representative of Starmark, and also is a 

member of Defendant Paul Commins trading team. 

(a) Defendant Thompson’s minute to the minute pattern of adding to his 

May Contract short position on April 20 is almost identical to and holds an 

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extremely high correlation (.979) with the patterns in which Defendants Paul 

Commins, Pickering, Younger, Roase, Lunn and Demetriou added to their May 

Contract short positions on April 20. See ¶¶ 142-143. Such high correlations with 

one trader, much less many traders, have an extremely low likelihood of occurring 

by chance or randomly independent trading decisions. 

(b) Defendant Thompson exploited the TAS device to place selling pressure 

in the May Contract by selling Contracts and avoid placing offsetting 

purchase pressure in the May Contract by purchasing TAS contracts on April 

20. 

(c) Defendant Thompson sold a large portion of his May Contracts in an 

aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading. 

55. Defendant is a natural person

residing 

. Defendant also maintained an 

account with Vega, completed compliance oversight training with Starmark to 

qualify as and later registered with the FCA as an authorized representative of 

Starmark, and also is a member of Defendant Paul Commins trading team. 

Defendant worked with other Vega Defendants to depress the prices of the 

Trader 10 Trader 10 Trader 10

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May Contract on April 20. Among other things, Defendant communicated 

with other Vega Defendants about the May Contract, put selling pressure into the 

May Contract on April 20 by net selling May Contracts, and avoided putting 

offsetting buying pressure into the May Contract by purchasing TAS contracts. 

Defendant sold a large portion of his May Contracts in an aggressive 

manner and used his May Contracts as “ammo” during April 20, including during 

the last hour of trading. See ¶¶139, 145 below.

56. Defendant Paul William Sutton is a natural person residing 

Defendant Sutton also maintained an account with Vega, is also 

registered with the FCA as an authorized representative of Starmark, and also is a 

member of Defendant Paul Commins trading team. Defendant Sutton worked with 

other Vega Defendants to depress the prices of the May Contract on April 20. 

Among other things, Defendant Sutton communicated with other Vega Defendants 

about the May Contract, put selling pressure into the May Contract on April 20 by 

net selling May Contracts, and avoided putting offsetting buying pressure into 

the May Contract by purchasing TAS contracts. Defendant Sutton sold a large 

portion of his May Contracts in an aggressive manner and used his May Contracts 

as “ammo” during April 20, including during the last hour of trading. See ¶¶139, 

145 below.

Trader 10 Trader 10

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57. Defendant is a natural person residing in the 

. Defendant also maintained an account with Vega, completed 

compliance oversight training with Starmark to qualify as an authorized 

representative of Starmark, and also is a member of Defendant Paul Commins’ 

trading team. Defendant worked with other Vega Defendants to depress the 

prices of the May Contract on April 20. Among other things, Defendant 

communicated with other Vega Defendants about the May Contract, put selling 

pressure into the May Contract on April 20 by net selling May Contracts, and 

avoided putting offsetting buying pressure into the May Contract by purchasing 

TAS contracts. Defendant sold a large portion of his May Contracts in 

an aggressive manner and used his May Contracts as “ammo” during April 20, 

including during the last hour of trading. See ¶¶139, 145 below.

58. Defendant James Michael Biagioni is a natural person residing 

Defendant Biagioni also maintained an account with Vega, is also 

registered with the FCA as an authorized representative of Starmark, and also is a 

member of Defendant Paul Commins trading team. Defendant Biagioni worked 

with other Vega Defendants to depress the prices of the May Contract on April 20. 

Among other things, Defendant Biagioni communicated with other Vega 

Trader 7 Trader 7 Trader 7 Trader 7 Trader 7

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Defendants about the May Contract, put selling pressure into the May Contract on 

April 20 by net selling May Contract, and avoided putting offsetting buying 

pressure into the May Contract by purchasing TAS contract. Defendant Biagioni 

sold a large portion of his May Contracts in an aggressive manner and used his 

May Contracts as “ammo” during April 20, including during the last hour of 

trading. See ¶¶139, 145 below. Defendant Biagioni made price moving trades 

for Defendant Sutton between 13:31:21 and 13:31:24. These trades were 

transferred to Defendant Sutton after Defendant Biagioni made them.

59. Starmark Investment Management Limited is a private limited 

company organized and existing under the laws of the United Kingdom, formed on 

June 3, 1998, and having a registered office and principal place of business in 

London, England. Starmark has a supervisory role over Defendant Vega Capital 

that initiated with the latter’s FCA registration as an Appointed Representative of 

Starmark, its Principal, from October 26, 2017 through August 13, 2019, the day 

Vega Capital’s FCA registration terminated. Vega has a supervisory role of 

Defendant Spires who is a representative of Starmark.

60. Eldon John Kerr, Starmark’s co-founder, “currently focuses on 

monitoring Appointed Representative and CF30 trading activity,” according to 

Starmark’s website. As such, Mr. Kerr would have supervised Vega Capital in its 

role as Starmark’s Appointed Representative until August 13, 2019. Despite the 

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termination of Vega Capital’s FCA registration as an Appointed Representative of 

Starmark on such date, Mr. Kerr’s inclusion by GH Financials on April 21, 2020 

correspondence with Vega Capital regarding the previous day's trading 

irregularities suggests that Starmark’s supervisory role over Defendant Spires or 

Defendant Vega’s trading activities persists.

61. In addition to its supervisory role over Defendant Vega, Starmark also 

directly supervises Defendants James Biagioni, Paul Commins, Aristos Demetriou, 

Henry Lunn, Elliott Pickering, Christopher Roase, Adrian Spires, Paul Sutton, 

Matthew Thompson and Connor Younger, all of whom are registered with the 

FCA as Starmark representatives. 

62. (a) Vega John Doe #1. Unknown Vega Defendant is one of the Vega

accounts. This Defendant financially benefited from the manipulation of the May 

Contract by Defendant Vega and the Vega Trading Defendants. 

(b) Vega John Doe #2. Unknown Vega Defendant is one of the Vega

accounts. This Defendant financially benefited from the manipulation of the May 

Contract by Defendant Vega and the Vega Trading Defendants. 

(c) Vega John Doe #3. Unknown Vega Defendant is one of the Vega

accounts. This Defendant financially benefited from the manipulation of the May 

Contract by Defendant Vega and the Vega Trading Defendants. 

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(d) Vega John Doe #4. Unknown Vega Defendant is one of the Vega

accounts. This Defendant financially benefited from the manipulation of the May 

Contract by Defendant Vega and the Vega Trading Defendants. 

63. John Doe Defendants 20-100 are persons or entities who worked with 

Defendants or on whose behalf Defendant Vega Capital worked to manipulate and 

fix prices of NYMEX crude oil futures contracts. 

64. G.H. Financials, LLC (“GHF LLC” or “GHF”) has been a Delaware 

corporation since May 31, 2011. GHF became operational as a clearing Futures 

Commission Merchant the same year. An FCM is a futures broker. As such, it 

solicits or accepts orders to buy or sell futures contracts, and accepts money or 

other assets from customers to support such orders. GHF was Defendant Vega’s 

broker until shortly after April 20, 2020 and made, as Vega’s agent the sales on the 

May Contract. 

65. GHF LLC is regulated by the Chicago Mercantile Exchange (“CME”)

which is a Delegated Self-Regulatory Organization (“DSRO”) on behalf of the 

CFTC. 

66. GHF LLC is located at 311 South Wacker Drive, Suite 1550, Chicago, 

Illinois 60606, and is a member of the National Futures Association 

(“NFA”). GHF LLC also holds memberships on the CME, NYMEX and ICE 

Futures US. 

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67. GHF acted as the FCM. 

 On April 20, Vega was the customer of GHF which made all the 

manipulative trades alleged herein. GHF was the FCM and exchange member 

which made all those trades. The accounts held by the Vega Trading Defendants 

were sub accounts of the Vega accounts under the designation with 

different sub accounts. 

68. G.H. Financials Limited is a Private limited Company incorporated on 

January 4, 1993 and registered at Companies House as No. 02775278, with the 

nature of its business defined as security and commodity contract dealing activities 

(SIC 66120) and its registered office located at 29 Ludgate Hill, 4th Floor, London 

ECAM 7JR (“GHF Ltd”). See: https://find-and-update.companyinformation.service.gov.uk/company/02775278

BACKGROUND 

A. Commodity Futures; How Futures Contract Trading Profits Or 

Losses Are Determined Using The May Contract As An Example. 

69. A person may act as a futures contract exchange or board of trade 

only if that person is approved and designated to do so by the Commodity Futures 

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Trading Commission. The CFTC approves such a designation only if the proposed 

exchange sufficiently demonstrates (a) that it has rules, such as position limit rules, 

to prevent price manipulation, and (b) that it has procedures to enforce such antimanipulation rules. 

70. The NYMEX is designated by the CFTC as a board of trade. 

NYMEX is the world’s largest physical commodity futures exchange. The 

NYMEX applies to the CFTC for permission to trade each commodity in which the 

NYMEX offers a contract. The NYMEX must establish, among other things, that 

the proposed contract is not prone to price manipulation in order to win approval to 

trade such contract. NYMEX members and clearing members have to follow the 

rules of the NYMEX. This includes the most important rules, the rules prohibiting 

manipulation. 

71. Also, commodity futures professionals licensed as associated persons, 

futures commissions merchants, commodity trading advisors, and commodity pool 

operators are required to be familiar with CFTC and exchange requirements. This 

includes the most important requirements, those prohibiting price manipulation. 

72. A commodity futures contract is an agreement to buy or sell a 

commodity, such as WTI, at a date in the future. Futures contracts are bilateral 

contracts with two sides. The “long” side is the buyer of the contract. The buyer is 

obligated to take delivery and pay for the commodity if the buyer holds the 

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contract until the specified delivery dates. Buyers are referred to as “longs.” The 

“short” side of the futures contract is the seller of the contract. The seller is 

obligated to make delivery of the commodity on the delivery dates. Sellers are 

referred to as “shorts.” 

73. Almost every aspect of a futures contract is standardized, except the 

price and quantity. Futures markets are specifically designed to facilitate and ease 

trading in one central marketplace for traders who are located throughout the 

United States and the world. 

74. In practice, very few deliveries occur and most futures contracts are 

satisfied or “liquidated” in the trading market. For example, significantly less than 

1% of all WTI futures contracts traded result in deliveries. Well over 99% of the 

WTI futures contracts which are traded are satisfied through liquidation trading. 

75. In order to satisfy a futures contract through trading in the futures 

market, a trader who holds a long position of one contract sells one contract. That 

creates one long position and one short position in such futures contract for the 

trader. These offsetting positions cancel out or liquidate the trader’s obligations to 

purchase a commodity and make delivery of a commodity under the contracts. 

Likewise, a trader who holds a short position of one contract buys one contract in 

order to trade out of the position. This, again, creates one long position and one 

short position for such trader. And this, again, cancels and liquidates the trader’s 

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original obligation to deliver the commodity by creating a separate obligation to 

purchase the commodity. 

76. The difference between the price at which a trader buys the contract 

and the price at which the trader sells the contract establishes the profit or loss on 

the contract. 

77. For example, suppose a trader sold one May Contract to establish a 

short position. Suppose the trader purchased back such May Contract later on the 

same day. Suppose that the sales price was $2.50 per barrel. Suppose that the 

purchase price was minus $37.50 per barrel. In this example, the profit (exclusive 

of trading commissions) would be $40.00 per barrel. Each May Contract consists 

of 1,000 barrels of WTI crude oil. The profit on that one contract (exclusive of 

commissions) would be $40,000.00. 

78. Open interest is defined as the total number of futures contracts in a 

delivery month or market that has been entered into and not yet offset or cancelled. 

Each open transaction has a buyer (a long) and a seller (a short). The open interest 

in commodity futures contracts tends to fluctuate from day to day. The open 

interest and trading volumes in a futures contract begin to decrease very 

substantially during the last month of trading in a futures contract. As such contract 

approaches its final expiration date and all trading must cease, the last few days of 

trading the volume and open interest continue to their lowest levels. 

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B. The WTI Contract 

79. One of the futures contracts traded on the CME is the light sweet 

crude oil (WTI) futures contract. The size of a WTI crude oil futures contract is 

1,000 barrels. The WTI crude oil futures contracts call for settlement by physical 

delivery at a variety of pipelines or storage facilities in or around Cushing, 

Oklahoma. 

80. Pursuant to NYMEX and CME rules, trading is conducted in WTI 

futures contracts expiring in each calendar month from the current month and 

continuing for the next ten calendar years plus two additional contract months. 

Trading in WTI crude oil futures contracts terminates on the third business day 

prior to the twenty-fifth calendar day of the month preceding the delivery month. 

If the twenty-fifth calendar day is not a business day, trading terminates four 

business days prior to the twenty-fifth calendar day of the month prior to the 

contract month. 

81. Daily settlement prices of WTI crude oil futures are settled at the 

volume-weighted average price (“VWAP”) of trades occurring on CME Globex 

between 1:28 and 1:30 p.m. Midwest time. The settlement price for the active 

month contract is determined by trades in the active month and trades in other 

contract expirations are determined by calendar spread transactions. 

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82. Trading in WTI crude oil futures contracts is subject to the rules and 

regulations of the NYMEX and CME, and prices are quoted in U.S. dollars and 

cents per barrel. 

83. The crude oil marketing hub in Cushing, Oklahoma is the most 

significant marketing and trading hub for crude oil in North America. Cushing 

serves as the delivery point for light sweet crude oil futures contracts traded on the 

CME. 

84. WTI crude oil is one of the most actively traded domestic crude oils, 

operates as the United States benchmark grade and is the primary deliverable grade 

under the WTI crude oil futures contracts. 

85. Like other commodity futures contracts which call for physical 

delivery, the open interest (see ¶79) and the daily trading volume in a WTI futures 

contract tend to decline dramatically as the last days of trading and the beginning 

of deliveries approach. 

86. In Trading at Settlement (or “TAS”) for WTI contracts, a market

participant agrees to purchase or sell a WTI futures contract at a price that is to be 

determined by the end of day settlement price of a particular WTI futures contract. 

87. Trade at Settlement is a capability that allows a commodities trader to 

execute an order to buy or sell an eligible futures contract at the settlement price or 

at a spread to the settlement price. The spread may be at a price up to a specified 

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number of ticks (minimum price fluctuations) above or below the settlement price 

for that particular type of commodity contract. See e.g., 

www.theice.com/publicdocs/futures us/TAS FAQ.pdf 

88. Similarly, traders who buy TAS contacts as they sell May Contracts 

have a motive to depress prices in order to make the prices approaching and at the 

end of the day as low as possible. Again, the cost band for TAS contracts is from 

minus ten cents to plus ten cents on the outright contracts, and minus twenty cents 

to plus twenty cents on the spreads. The NYMEX Rulebook provides: “Unless 

otherwise specified by the Exchange, a TAS transaction may be executed at the 

current day’s settlement price or at any valid price increment ten ticks higher or 

lower than the settlement price.” Chapter 5, Section 524.A.3 (TAS Transactions), 

available at: 

https://www.cmegroup.com/content/dam/cmegroup/rulebook/NYMEX/1/5.pdf 

89. There are separate bids and offers for TAS contracts than for WTI 

contracts. TAS contracts are bought and sold at a price differential from the daily 

settlement price, so the final price of the TAS contract is the settlement plus or 

minus a premium or discount. The allowable price increments and differential are 

defined by NYMEX. See Interim Staff Report; Trading in NYMEX WTI Crude Oil 

Futures Contract Leading up to, on, and around April 20, 2020 (CFTC Nov. 23, 

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2020). In the TAS contract market, the price may range ten ticks higher or lower 

than the settlement price. NYMEX Rule 524. 

90. TAS contracts may serve valuable functions in physical delivery

markets, including by allowing institutions and others to pay a small sum in order 

to lock in a trade at the settlement price determined between 1:28 and 1:30 pm 

Chicago time for a given WTI contract. However, even in well-designed and wellregulated futures contracts such as the WTI futures contract, the use of TAS 

contracts is subject to abuse when certain constraints exist in the market. See 

¶¶107-112 below. 

91. As recently stated by CFTC Commissioner Dan Berkovitz on 

November 24, 2020: “The potential for TAS trading to artificially affect the 

settlement price of a contract is well known; indeed, the CFTC has brought two 

enforcement cases based on the use of TAS to manipulate the price of futures 

contracts.” See 

https://www.cftc.gov/PressRoom/SpeechesTestimony/berkovitzstatement112320a. 

Commissioner Berkovitz also expressed his view that the CFTC should look into 

the TAS trading activity in its investigation of the precipitous drop and rebound of 

WTI oil trading prices on April 20-21. 

C. Buying Pressure, Selling Pressure, Cumulative Net Sales And 

Cumulative Selling Pressure 

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92. All else equal, sales of futures contracts exert downward pressure on 

prices, and the larger the number of sales, the greater the downward pressure on 

prices. All else equal, purchases of futures contracts exert upward pressure on 

prices, and the greater the number of purchases, the greater the upward pressure on 

prices. 

93. All else equal, the more that a market participant (or a group of 

market participants) sells a commodity futures contract and the less that they say a 

commodity futures contract during a trade day, the more cumulative net sales they 

will make and downward pressure on prices that they exert. 

94. All other things equal, buying pressure in a commodity futures 

contract will tend to make prices higher than they otherwise would have been. 

Selling pressure in a commodity futures contract will tend to make prices lower 

than they otherwise would have been. 

95. Bids are orders to buy a futures contract. Offers are orders to sell a 

futures contract. When the highest bid equals or exceeds the lowest offer, an 

agreement to purchase and sell a futures contract is made. Because the prices in the 

futures market are determined by the lowest offer and the highest bid, the futures 

markets are sometimes referred to as a dual auction market. After the match 

creating an execution, the bid and offer are removed from the order book to the 

extent of the match. The remaining bids and offers determine the prices. 

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96. Orders to purchase or sell may be submitted in two general types. One 

is a “limit” order, which is an order to sell or buy at a price limit. A bid for $10 per 

barrel or better, is a bid to buy at a maximum of $10 and less than $10 if possible. 

An offer to sell at $10 per barrel is an offer to sell at $10 per barrel or higher, but 

not less than $10 per barrel. 

97. A market order is an order to buy at or above the available offer, or to 

sell at or below the available bid in the market. Limit orders which seek to buy at 

or above the lowest offer or sell at or below the highest bid are, in effect, market 

orders to that extent.4

 A market order to sell 10 contracts is an offer to sell 10 

contracts at whatever the bid is in the market. If there are three contracts bid at $10 

per barrel, three contracts bid at $9.95 per barrel, three contracts bid at $9.90 per 

barrel, and one contract bid at $9.85 per barrel, the 10 contract market offer will, 

all other things equal, remove all of those from the order book and execute with the 

last price of $9.85 per barrel. The bid after that transaction will be whatever the 

highest bid is below $9.85 per barrel. 

98. All other things equal, market order sells exert downward pressure on 

prices and market order buys exert upward pressure on prices. 

99. Making offers to sell below the highest bid in a volume greater than 

the highest bid causes prices to decline and “sells through the market”. This 

4

 These are sometimes referred to as “marketable limit orders”. 

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removes from the order book the bids at the higher level. This is a sufficient, but 

not necessary condition to cause prices to decline. 

100. This can also execute the next bids and, depending on the size of the 

marketable offers and the size of the bids, take them out of the order book. If a 

trader adds marginal (i.e., extra) offers to a market which exceed the bids in the 

market at a given price, then the trader or traders will cause prices to move down. 

101. If a trader is able to add marginal offers at a given price that cause the 

total offers to exceed the total bids, then there will be downward pressure on prices 

and prices will move down. This is a significant but not a necessary condition to 

depress prices. 

The United States Commodity Futures Trading Commission And The United 

Kingdom Financial Control Authority Have Recognized That The Use By 

Traders Of Their Trades As “Ammo” Constitutes A Manipulative Device

102. Regulators recognize that “ammo” is a term used by manipulators. 

Although the exact meaning of “ammo” varies in the context of the specific 

manipulation, the use of the term “ammo” signifies possession of the ability to 

make a quantity of transactions in a manner in which the transactions will depress 

or inflate futures contract prices. 

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103. The FCA has previously explained that the use of the word “ammo” 

was part of a manipulative strategy to influence prices.5

 

104. The United States Commodity Futures Trading Commission also 

recognized the use of the term “ammo” as being part of a manipulative device in 

the consent order in ISDAFix. There, the CFTC stated that “...traders would use 

limited "ammo" and timing techniques to attempt to manipulate...”. 

https://www.cftc.gov/sites/default/files/idc/groups/public/@lrenforcementactions/d

ocuments/legalpleading/enfroyalorder020317.pdf 

105. The CFTC, in providing “Examples of Misconduct in Private Chat 

Rooms”6

, discusses the use of the word “ammo”. In an example under the 

heading, “Traders Share ‘Ammo’”, the CFTC quotes a conversation where traders 

at different banks discuss “more ammo for you....” 

UNDERLYING ALLEGATIONS 

A. The Abuse Of TAS Transactions To Manipulate Prices 

5 https://fcalegacy.videomarketingplatform.co/secret//62508029/a45a0407be96952c359daa5be8158bcc

(video presentation showing multiple firms using the phrase “leaving you with the ammo” as part 

of the collusive conversation in an attempt to fix and move rates); see also FCA Final Notice 

against UBS, https://www.fca.org.uk/publication/final-notices/final-notice-ubs.pdf. 

https://www.ft.com/content/47c32ec4-6a34-11e4-8fca-00144feabdc0 (“Furthermore, traders in a 

chatroom with net orders in the opposite direction to the desired movement at the fix sought to 

transact before the fix with traders outside the chatroom. The FCA said this practice was 

commonly referred to as “leaving you with the ammo”, building the volume of orders held by the 

traders in the chatroom in the desired direction and increasing their potential influence on the 

fix.”) 

6

https://www.cftc.gov/sites/default/files/idc/groups/public/@newsroom/documents/file/hsbcmisco

nduct111114.pdf 

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106. The use of TAS contracts may cause a fragmentation of order flow. 

Part of the order flow to purchase and sell, in this case, May Contracts, goes into 

the bids and asks for May Contracts. A different part of the order flow to purchase 

and sell May Contracts may be put into the TAS market. 

107. Peer reviewed economic literature shows that this “fragmentation” of 

order flow into two different markets tends to (a) cause individual orders for the 

futures contract (here the May Contract) to have somewhat greater price impact; 

and that the purchase order in the TAS market does not exert buying pressure 

which offsets or equals the selling pressure in the futures contract, here the May 

Contract. Craig Pirrong, The Economics Of Commodity Market Manipulation: A 

Survey, Journal of Commodity Markets, Vol. 5, pp. 1-17, (March 2017). 

108. Thus, persons who purchased TAS contracts prior to or as they sell 

May Contracts during April 20, create for themselves an increasingly large 

financial interest in lower settlement prices for the May Contract. After their May 

Contract sales and TAS purchases go beyond an insignificant amount, certain types 

of traders have an increasingly large motive to make large net sales of the May 

Contract in order to exert downward pressure on the settlement price and create a 

profit for themselves. 

109. Similarly, this type of manipulative trader, also has a large financial 

motive to recruit an increasingly large group of traders to follow the same modus 

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operandi of selling the futures contract and buying the TAS contract. Combined, 

this group can exert cumulative net selling pressure on the (in this instance) May 

Contract as the day progresses. 

110. Then, as the end of trading approaches (in the last hour or half hour of 

trading), this type of trader has a motivation to ramp up their own sales to a large 

percentage of the market and exert further causation of depression through 

blatantly using their sales as “ammo” to depress prices. 

111. By doing the foregoing and also combining with other traders, this 

type of trader can bring its maximum pressure to bear on prices at the end of 

trading. Specifically, as the trading group’s net cumulative sales of the futures 

contract are reaching their highest levels and reaching the most cumulative 

downward effect on prices (by removing the largest cumulative amounts of bids 

from the order book), the trading group also increases its percentage of sales in the 

market and does so in an aggressive manner that converts that significant 

percentage of the share of the sales in the market into the manipulative device of 

“ammo”. Both the large percentage of sales and the greater impact per sale of 

making the sale as “ammo” (i.e., very aggressively to intentionally move down 

prices) exert separate and further downward impacts on prices. 

112. The foregoing profile is exactly what the Vega Trading Defendants 

did in the May Contract. 

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B. Defendant Commins’ background and formation of a group that could 

execute a TAS manipulation. 

113. Defendant Paul Commins 

 Defendant Commins 

 

114. Traders on the IPE reportedly combined together to make transactions 

in opposition directions in the futures contract and related TAS contract. For 

example, they would purchase the TAS contract and sell the futures contracts. By 

engaging in increasing selling as the day wore on, the IPE traders could cause the 

TAS contract prices to be lower. By depressing the TAS price, they IPE futures 

traders could make a profit on the difference between their higher priced sales 

earlier in the day and their lower prices at which they purchased at the end of the 

day by virtue of the lower settlement they caused and which, through the TAS 

mechanism, became their purchase price. 

115. After the closing of the IPE, former floor traders banded together at 

“arcades” or “prop” (proprietary trading) shops with five of these groups, known as 

the “five families” based in London. One advantage of having these groups is that 

they could exploit the TAS mechanism exactly by trading in a group. 

116. Reportedly, Defendant Commins and other traders worked for one of 

the “five families” – – for a long time. 

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117. However, Defendant Commins then reportedly started his own group 

which consists at least of the other Vega Trading Defendants. 

118. Reportedly, the Vega Defendants frequently make trades in the same 

contracts at around the same time to move prices. 

119.

120. Defendant Spires and 

Commins

121.

 That is, the 

Vega Trading Defendants commit their trading capital to fund one another’s risks, 

which is similar to a joint venture in which the co-venturers commit their trading 

capital to help any member of the combine. 

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122.

 Defendants Matthew Thompson and Paul 

Sutton 

Defendant Paul Commins 

123. Defendant

Commins Defendants Thompson 

and Sutton. 

124. Also, Vega has a financial motive to see that Thompson and Sutton 

are in a position to try to make lots of profits; however, provided that the pool of 

capital is sufficient from the Vega Traders, Vega has no downside. I.e., the more 

risk that Thompson and Sutton take, the more that Vega stands to gain. 

125. Defendant Paul Commins 

 

7

 VEGA_M1SH_000042676 

8

 VEGA_M1SH_000042676 

9 See https://find-and-update.company-information.service.gov.uk/company/07158619

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126. Thus, Defendant Commins speaks on behalf of all the other 

Defendants. In such position, Defendant Commins not only knows the reasons 

behind what each trader was doing, but that the reasons were the exact same. 

127. When people act for exactly the same reasons, they are more likely to 

be in an agreement, especially if an agreement to combine together makes them 

more likely to achieve their goals and make their reasons work out. This is even 

more true when the reasons are a market power manipulation in which the traders 

are combining their cumulative net sales of the May Contract and separate 

purchases of TAS contracts to have the largest financial motive to manipulate and 

the largest ability to manipulatively depress May Contract prices at the close of 

trading on April 20. Finally, what they were doing on April 20 is exactly parallel to 

a TAS manipulation (described in ¶¶87-92, 107-113 above) and the type of TAS 

manipulations that occurred on the IPE (described in ¶¶114-116 above). It is also a 

type of manipulation which “families” of traders are well positioned to engage. See 

¶¶116-117 above. Reportedly, Commins and other traders at Vega vacation 

together, socialize together, and drink together. 

C. The Vega Defendants Manipulative Depression of May Contract 

Prices 

128. On April 20th, the Vega Defendants believed that the May Contract 

was in its next to last day of trading and was a “thin” market in which there was 

not great depth of trading and orders to purchase. The Vega Defendants believed 

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that the May Contract was vulnerable to price depression by a concerted group of 

traders pursuing the following method. The traders would exert an increasing 

cumulative net selling pressure on the May Contract. As that cumulative net selling 

pressure reached high levels, the Vega Defendants would use their sales as 

manipulative “ammo”. See above. The use of the “ammo” would both depress 

prices directly, and also increase Vega’s rate of sales and the percentage of the 

total volume of May Contract sales that the Vega Defendants’ sales constituted. 

This combination of increasing cumulative net selling pressure (which had been 

removing purchase orders from the market), the use of manipulative “ammo” sales, 

and the large increases in Vega’s percentage of the overall volume of sales in the 

market would manipulatively depress May Contract prices during April 20th

including at the time of the determination of the TAS. Thereby, the Vega 

Defendants would reap substantial profits from the higher prices at which they 

made their May Contract sales and the lower prices at which they would purchase 

as determined by the artificially depressed settlement price. 

129. As with all manipulations, there were risks to the manipulators of the 

success of their manipulation. But the Vega Defendants reportedly had prior 

experience with trading together at the same times to move prices. And they 

successfully executed their manipulative depression of May Contract prices. 

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130. On April 20th, the May Contract price was approximately $11.69 per 

barrel at 9:00 a.m. in Chicago. From at or about 9:00 am on April 20th until at or 

about 11 am, the May Contract price declined from $11.69 to $10.33. During this 

time, the Vega Defendants placed increasing cumulative net selling pressure on the 

May Contract price. This caused the May Contract prices to be lower than they 

otherwise would have been. 

131. Similarly, during the next time periods of the day (alleged below) the 

Vega trading Defendants continued to increase their cumulative net selling 

pressure on the May Contract price. During each of these periods, the Vega 

Trading Defendants placed increasing cumulative net selling pressure on the May 

Contract and caused the May Contract prices to be lower than they otherwise 

would have been. 

132. A manipulator seeks to sell at a high price and buy at a low price. The 

Vega Defendants followed this pattern. They exerted less pressure on May 

Contract prices until their cumulative net selling pressure had built up a substantial 

short position in the May Contract and a substantial TAS position to liquidate 

(purchase back) that short position at whatever that May Contract price turned out 

to be at the end of trading. 

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133.

 

134. During this time period, the Vega Defendants 

a. Substantially increased their number of May Contracts sold per 

minute. 

b. Substantially increased their percentage of the total sales of May 

Contracts made by the entire market. 

c. Exerted greater depressive impact on prices, per each new May 

Contract sold, by selling in a manipulative “ammo” fashion. 

135. During the Vega Defendants’ final frenzy of manipulative ammo 

selling, they caused and help cause the May Contract to move into negative prices 

for the first time in history, and to experience the vast majority of its all-time 

record price decline on April 20th during a brief 20 minute period between 1:08 and 

1:28 pm. 

136. Specifically, due to the combination of all Vega’s foregoing steps, the 

May Contract declined from minus one penny per barrel to as low as minus 42 

dollars per barrel. 

D. The Vega Trading Defendants Combined, Conspired and Worked In 

Concert For The Purpose of Depressing the Price of the May 2020

WTI Crude Oil Futures Contract on April 20, 2020 

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137. On April 20, 2020, each Vega Trading Defendant engaged in the 

exact same manipulative strategy: purchasing May Contracts via TAS and 

selling May Contracts for the purpose of depressing its price, which also allowed 

them to increase their position limits because they had less risk of the TAS.10 

Having purchased large volumes of May Contracts via TAS, the Vega Trading 

Defendants had a large financial incentive for the price of the May Contract to go 

lower. 

138. On the trading day for April 20, 2020, each of the below Vega 

Trading Defendants purchased May Contracts via TAS and sold May Contracts in 

approximately the amounts set forth below. In total, the Vega Trading Defendants 

sold approximately May 2020 Contracts 

and purchased approximately May Contracts via 

TAS.11 The Vega Trading Defendants’ profits in connection with their trading of 

the May Contract on April 20, 2020 totaled approximately 

a. Defendant Connor Younger 

10 Transactions in the May Contract, including sales, move prices. TAS transactions in the May 

Contract, including TAS purchases, have minimal or sometimes no impact on prices. 

11 On the trading day for April 20, 2020, the Vega Trading Defendants purchased approximately 

 May 2020 NYMEX WTI futures contracts via outright trades. Approximately 40% of these 

purchases came after 1:30 p.m. On the trading day for April 20, 

2020, the Vega Trading Defendants sold May Contracts via TAS. 

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b. Defendant Elliott Pickering 

c. Defendant Aristos Demetriou 

 

d. Defendant Henry Lunn 

e. Defendant Christopher Roase 

 

f. Defendant 

g. Defendant Mathew Thompson 

 

h. Defendant Paul Commins

Trader 7 Trader 7

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i. Defendant George Commins 

j. Defendant Paul Sutton 

k. Defendant 

 Defendant 

l. Defendant James Biagioni

m

Trader 10 Trader 10

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 Connor Younger

 Elliott Pickering

 Aristos Demetriou 

 Henry Lunn 

 Christopher Roase 

 Matthew Thompson 

 Paul Commins 

 George Commins 

 Paul Sutton 

 James Biagioni 

140. Despite representing to the CME that the Vega Trading Defendants 

acted “independently” on April 20, 2020 (see ¶¶ 37, 126), the five Vega Trading 

Defendants with the highest volume of May Contract sales (approximately 69% of 

Vega’s total sales)—Defendants Younger, Pickering, Demetriou, Lunn and 

Roase—sold May Contracts in virtual lockstep as reflected in the below chart. 

Based upon information and belief, Plaintiff alleges that the Vega Trading 

Defendants entered trades manually, and not by computer program. 

Trader 7 Trader 10

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141. A statistical correlation analysis of the minute-by-minute positions of 

Defendants Younger, Pickering, Demetriou, Lunn and Roase reflects that these 

five traders’ positions in the May Contract on April 20 were very highly correlated. 

Specifically, the minute-by-minute positions of these five traders in the May 

Contract had an extremely strong tendency (between 96.2% and 99.7%) to move 

in the same direction at the very same time throughout the day on April 20. 

Demetriou Roase Lunn Younger Pickering 

Demetriou 

Roase 

‐3500

‐3000

‐2500

‐2000

‐1500

‐1000

‐500

0

500

9.009.159.309.459.609.759.90

10.0510.2010.3510.5010.6510.8010.9511.1011.2511.4011.5511.7011.8512.0012.1512.3012.4512.6012.7512.9013.0513.2013.3513.5013.6513.80

Contracts

Time

Vega Traders' K20 Positions by Minute on 4/20/2020

Series1 Series2 Series3 Series4 Series5 Series6

Series7 Series8 Series9 Series10 Series11 Series12

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Lunn 

Younger 

Pickering 

142. Further, each of the above Defendants additions to its positions was 

highly correlated with those of Defendant Paul Commins. 

Defendant Defendant Paul Commins 

Defendant Younger 

Defendant Demetriou 

Defendant Pickering 

Defendant Roase 

Defendant Lunn 

143. In order to depress the price of the May 2020 NYMEX WTI crude oil 

futures contract (and thereby reap large profits by purchasing via TAS May 

Contracts at an extremely low price), the Vega Trading Defendants combined and 

conspired to sell large volumes of May Contracts in the final hours before the 

settlement price of the May Contract was to be determined at approximately 1:30 

p.m. CST on April 20. See below. 

144. As detailed below, the Vega Trading Defendants’ large sales of the 

May Contract constituted an increasingly larger share of the total trading volume 

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of the May Contract (growing to more than 30% of the total volume during the last 

approximately 22 minutes of trading) at the same times that the prices of the May 

Contract were increasing their rate of decline. Specifically: 

a. During the time period 9:00 a.m. CST until 11:00 a.m. CST on April 

20, 2020, the Vega Trading Defendants sold approximately 

May Contracts, which constituted approximately 6.7% of the total 

volume in the May Contract during the same time period. During this 

time period, the Vega Trading Defendants sold, on average, May 

Contracts per minute. The price of the May Contract decreased by 

approximately $1.36 per barrel from 9:00 a.m. CST (approximately 

$11.69 per barrel) to 11:00 a.m. CST ($10.33 per barrel). 

i. Defendant Elliott Pickering 

ii. Defendant Aristos Demetriou

iii. Defendant Christopher Roase

iv. Defendant Conor Younger 

v. Defendant 

vi. Defendant Paul Commins

vii. Defendant Henry Lunn

Trader 7

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viii. Defendant Matthew Thompson

ix. Defendant George Commins 

x. Defendant Paul Sutton

b. During the time period 11:00 a.m. CST until noon CST on April 20, 

2020, the Vega Trading Defendants sold approximately May 

Contracts, which constituted approximately 16.4% of the total volume 

in the May Contract during the same time period. During this time 

period, the Vega Trading Defendants sold, on average May 

Contracts per minute. The price of the May Contract decreased by 

approximately $5.41 per barrel from 11:00 a.m. CST (approximately 

$10.33 per barrel) to noon CST ($4.92 per barrel). 

i. Defendant Aristos Demetriou

ii. Defendant Elliott Pickering 

iii. Defendant Christopher Roase

iv. Defendant Henry Lunn

v. Defendant Conor Younger 

vi. Defendant 

Trader 7

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vii. Defendant Matthew Thompson

viii. Defendant Paul Commins

ix. Defendant George Commins 

x. Defendant 

xi. Defendant Paul Sutton

xii.

xiii. Defendant James Biagioni

c. During the last 1.5 hours of trading (noon CST until 1:30 p.m. CST), 

the Vega Trading Defendants sold approximately May 

Contracts, which constituted approximately 23.6% of the total volume 

in the May Contract during the same time period. During this time 

period, the Vega Trading Defendants sold, on average, May

Contracts per minute. The price of the May Contract decreased by 

approximately $42.55 per barrel from noon CST (approximately $4.92 

per barrel) to 1:30 p.m. CST (negative $37.63 per barrel). 

i. Defendant Conor Younger 

ii. Defendant Elliott Pickering 

Trader 10

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iii. Defendant Aristos Demetriou

iv. Defendant Henry Lunn

v. Defendant Christopher Roase

vi. Defendant Matthew Thompson

vii. Defendant 

viii. Defendant Paul Commins

ix. Defendant George Commin

x. Defendant Paul Sutton

xi. Defendant 

xii.

xiii. Defendant James Biagioni

d. During the last half hour of trading (1:00 p.m. CST to 1:30 p.m. CST), 

the Vega Trading Defendants sold approximately May 

Contracts, which constituted approximately 29.2% of the total volume 

in the May Contract during the same time period. During this time 

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period, the Vega Trading Defendants sold, on average, May

Contracts per minute. The price of the May Contract decreased by 

approximately $38.29 per barrel from 1:00 p.m. CST (approximately 

$0.66 per barrel) to 1:30 p.m. CST (negative $37.63 per barrel). The 

average price decline of the May Contract during this time period was 

approximately $1.28 a barrel per minute. 

i. Defendant Conor Younger 

ii. Defendant Elliott Pickering 

iii. Defendant Aristos Demetriou

iv. Defendant Matthew Thompson

v. Defendant Christopher Roase

vi. Defendant Paul Commins

vii. Defendant Henry Lunn

viii. Defendant George Commins 

ix. Defendant 

x. Defendant Paul Sutton

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xi. Defendant 

e. During the last approximately 22 minutes of trading (i.e., from the 

time when the first May Contract traded at a negative price 

(approximately 1:08:23 p.m. CST) until the 1:30 p.m. CST,) the Vega 

Trading Defendants sold approximately May Contracts, which 

constituted approximately 30.5% of the total volume in the May 

Contract during the same time period. During this time period, the 

Vega Trading Defendants sold, on average, May Contracts per 

minute. The price of the May Contract decreased by approximately 

$37.62 per barrel from approximately 1:08:23 CST (approximately

negative $0.01 per barrel) to 1:30 p.m. CST (negative $37.63 per 

barrel). The average price decline of the May Contract during this 

time period was approximately $1.71 a barrel per minute. 

i. Defendant Conor Younger 

ii. Defendant Elliott Pickering 

iii. Defendant Aristos Demetriou

iv. Defendant Matthew Thompson

v. Defendant Paul Commins

vi. Defendant George Commins 

Trader 10

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vii. Defendant Christopher Roase

viii. Defendant 

ix. Defendant Henry Lunn

x. Defendant Paul Sutton

xi.

E. Net Cumulative Aggressive Sales Pressure. 

145. Though not a necessary condition for manipulation, a sufficient

condition for manipulation the creation of significant net aggressive selling 

pressure on a futures contract. 

146. The CME provides an aggressor indicator in its market depth data for 

individual trades. The CME states 

“An aggressor is defined as any customer order that 

triggers a trade immediately upon entering the book. 

Tag 5797-AggressorSide indicates if the trade had an 

aggressor and, if so, which side of the book it was on. 

When an Aggressor Side is defined (1 = Buy, 2 = Sell), 

the first Order Detail level related to the Summary Level 

represents that aggressor order. 

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 The aggressor quantity (tag 32) in the first Order Detail 

entry is equal to the Summary Level fill quantity (tag 

271) 

 If the aggressor quantity (tag 32) in the first Order Detail 

entry is equal to the sum of the remaining Order Detail 

entries quantity associated with that Summary Level, 

only customer orders were filled in the trade 

 If the aggressor quantity (tag 32) is not equal to the sum 

of the remaining Order Detail entries quantity associated 

with that Summary Level, customer and implied orders 

were filled in the trade. The unreported quantity are the 

participating implied orders. 

 There may be only one Order Detail entry present, which 

means an aggressing customer order traded against 

implied orders only. 

 The aggressor quantity (tag 32) in the first Order Detail 

entry is not equal to the Summary Level fill quantity (tag 

271) 

 In this case, the aggressor joined a pool of resting orders 

and thereby created sufficient quantity to trigger a trade. 

 This scenario can occur in any ratio spread where a 

different minimum quantity is required for each leg in 

order for the spread to trade. Examples include IVR and 

butterfly spreads.” 

https://www.cmegroup.com/confluence/display/EPICSANDBOX/MD

P+3.0+-+Trade+Summary+Order+Level+Detail Last reviewed on 

1/22/2021. 

147. The CME describes the impact of an aggressor or an aggressing order 

as follows: 

An "Aggressor" or "Aggressing Order" by definition is an incoming 

order matching with one or more orders resting on the order book. 

The Aggressor pulls liquidity out of the order book by triggering a 

match event removing resting quantity and potentially price level 

from the order book. 

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The Aggressor is identified in each order match during the 

continuous trading period and reported on all three customer 

interfaces, Order Entry, Market Data, and Post-Matching/Clearing. 

There is no Aggressor indicator for trades occurring at the end of the 

market opening auction or any other state other than continuous

trading. 

https://www.cmegroup.com/confluence/display/EPICSANDBOX/Order+Function

alities [last reviewed on 1/22/2021]. 

148. The CME describes multiple situations in which a transaction is not 

assigned an aggressor tag even if it has the impact of matching with one or more 

orders resting on the order book (and thereby “removing resting quantity and 

potentially price level from the order book”). These situations include the use of 

the mixing of a spread order and outright order to create an implied order for the 

execution, and during the market open re-open resolution trades. 

https://www.cmegroup.com/confluence/display/EPICSANDBOX/MDP+3.0+-

+Trade+Summary+Order+Level+Detail [last reviewed on 1/22/2021].

149. Also, the CME does not report an aggressor tag for market open and 

re-open resolution trades. Id.

150. Likewise, for spread trading the CME states 

“For trades involving spread instruments, the Aggressor 

is reported at the spread level only. Meaning, that the 

aggressor flag is only present in the Fill Notice for the 

spread summary and the flag is not present in the Fill 

Notices submitted for the leg components of the spread.” 

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https://www.cmegroup.com/confluence/display/EPICSANDBOX/Order+Function

alities [last visited on 1/26/2021]. 

151. Accordingly, even transactions that do not appear in the CME 

aggressor column, may functionally constitute “aggressor” transactions if they 

remove resting bids or offers from the order book. 

152. The CME record of aggressor sales minus the aggressor purchases for 

a given period (e.g., April 20, 2020) is one indication of the cumulative net selling

pressure placed on the market during that period. 

153. If a market participant’s aggressive sales exceed that participant’s 

aggressive buys over a given period, then that participant will exert downward 

pressure on prices during that period. The greater the difference between the 

participant’s aggressive purchases and sales, the more selling pressure and the 

greater the decline in prices that participant will cause over that period, all else 

equal. The greater the percentage that a market participant’s net aggressive sales 

represent of the entire market’s net aggressive sales over a given period, the larger 

the proportion of the price decline during that period the market participant may 

cause. 

154. Total CME Net Aggressor Sales Of May Contracts On April 20. 

The CME Market Depth FIX records reflect aggressive sales of approximately 

47,077 May Contracts and aggressive purchases of approximately 20,769 May 

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Contracts on April 20. Subtracting the May Contracts transacted in aggressive 

purchases from the May Contracts transacted in aggressive sales on April 20, 

produces a net aggressive sales of May Contracts on April 20 of 26,306 contracts 

for the Chicago trading day from 9am. 

155. Through their coordinated selling pressure on the May Contract and 

their coordinated diversion of buying pressure into the TAS contract, the Vega 

Trading Defendants also made on April 20 aggressive sales of May Contracts that 

were much greater than their aggressive purchases of May Contracts. 

156. Estimating Vega’s Aggressive Sales. The CME has a column which 

designates trades as “aggressor” trades in its Order Entry, Market Data, and PostMatching/Clearing. A comparison between the exact prices and the exact times (to 

the nanosecond) of the transactions reflected in the CME’s Market Data as 

aggressive sales, with the exact prices and exact times (to the nanosecond) of 

Vega’s sales of May Contracts reflected in Vega’s records, produces an estimate of 

the approximate amount of aggressive sales made by the Vega Defendants during 

April 20. Based on this comparison, Plaintiff estimates that the Vega Defendants 

made aggressive sales of at least May Contracts on April 20.

157. Estimating Vega’s Aggressive Purchases. A comparison between 

the exact prices and exact times to the nanosecond of the transactions reflected in 

the CME market data as aggressive purchases, with the exact prices and exact 

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times (to the nanosecond) of Vega’s purchase of May Contracts reflected in Vega’s 

records, produces an estimate of the approximate amount of May Contracts of 

which Vega made aggressive purchases of approximately contracts on April 

20.

158. Based upon the comparison of the data sets, Plaintiff has good 

grounds to believe and does allege that Vega made aggressive sales of at least 

May Contracts and aggressive purchases of approximately May 

Contracts during April 20. Discovery is needed to determine the exact extent of 

Vega’s aggressor purchases and sales.

159. Estimating Vega’s Net Aggressive Sales. Subtracting Vega’s 

estimated aggressive purchases of contracts from Vega’s estimated aggressive 

sales of May Contracts on April 20 produces a net aggressive sales by Vega 

on April 20, of at least contracts. 

160. Estimating The Percentage That Vega’s Net Aggressive Sales 

Constituted Of The Entire Market’s Net Aggressive Sales On April 20. The net 

aggressive sales by Vega of May Contracts on April 20 constitutes 

approximately 26.4% of the total net aggressive sales of May Contracts by 

the entire market on April 20. 

161. Applying the same methodology as applied above to the time periods 

within May 20, Plaintiff has good grounds to believe and does allege as follows. 

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162. In addition to having a large share of the total volume of the May 

Contract, the Vega Trading Defendants had an even larger share of the cumulative 

total net aggressor sales. Specifically: 

a. From 9:00 a.m. CST until 11:00 a.m. CST, the Vega Trading 

Defendants had a minimum of approximately net aggressor sales 

of May Contracts out of a total of approximately net aggressive 

sales of May Contracts in the market during this same time 

period. Thus, the Vega Trading Defendants’ sales of May Contracts 

during this time period constituted at least of the total net 

aggressive sales of the total market during this time period. 

b. From 11:00 a.m. CST until noon CST, the Vega Trading Defendants

had a minimum of approximately net aggressor sales of May

Contracts out of a total of approximately net aggressive sales of 

May Contracts in the market during this same time period. Thus, the 

Vega Trading Defendants’ sales of May Contracts during this time 

period constituted at least of the total net aggressive sales of 

the total market during this time period. 

c. From noon CST until 1:30 CST, the Vega Trading Defendants had a

minimum of approximately net aggressor sales of May 

Contracts out of a total of approximately net aggressive sales 

of May Contracts in the market during this same time period. Thus, 

the Vega Trading Defendants’ sales of May Contracts during this time 

period constituted at least of the total net aggressive sales of 

the total market during this time period. 

d. From 1:00 p.m. CST until 1:30 p.m. CST, the Vega Trading 

Defendants had a minimum of approximately net aggressor 

sales of May Contracts out of a total of approximately net 

aggressive sales of May Contracts in the market during this same time 

period. Thus, the Vega Trading Defendants’ sales of May Contracts 

during this time period constituted at least of the total net 

aggressive sales of the total market during this time period. 

e. From 1:08:23 p.m. CST until 1:30 p.m. CST, the Vega Trading 

Defendants had a minimum of approximately net aggressor 

sales of May Contracts out of a total of approximately net 

aggressive sales of May Contracts in the market during this same time 

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period. Thus, the Vega Trading Defendants’ sales of May Contracts 

during this time period constituted at least of the total net 

aggressive sales of the total market during this time period. 

163. Plaintiff has good grounds to believe and does allege that discovery 

will show that the Vega Defendants exerted an increasing cumulative net 

aggressive selling pressure on the May Contract during April 20; that their net 

aggressive sales ramped up during the last hours, the last hour, and the last 30 

minutes of trading; and that the combination of these steps exerted a substantial 

downward effect on prices during April 20. 

F. High Degree Of Communications Among Most Vega Defendants And 

The Common Plan For Everyone To Be Short And Use Manipulative 

“Ammo” At The End Of Trading.

164. In furtherance of their agreement to depress May Contract prices, the 

Vega Trading Defendants communicated, in real time, about their sales of the May 

Contract and related matters. To do so, such Defendants employed text messages, 

group text messages, phone calls, and private “bulletin board” texting available via 

mobile phone “apps” such as “WhatsApp”. 

165. Through these means, the Vega Trading Defendants discussed their 

May Contract positions, their selling of WTI futures, their buying of TAS 

positions, and their plans for depressing WTI futures contract prices. 

166. Pursuant to Defendants agreement, Defendants Matt Thompson and 

Henry Lunn 

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167. By 1:05 Chicago time, Defendants had substantially ramped up their 

sales of May Contracts and their impact on prices. 

Defendants’ selling pressure on the May Contract had moved prices down and was 

getting very close to causing the May Contract prices to become negative. 

 Defendant Lunn 

 and Defendant Thompson 

 Also between 1pm and 1:30, the Vega Defendants increased their rate of 

sales to contracts per minute, and increased the amount of depression they 

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caused per contract sold through the use of the manipulative device of “ammo” 

sales. See allegations “D” immediately preceding this section. 

168. Pursuant to Defendants’ agreement, three Vega Trading Defendants 

Lunn, Connor and Pickering 

 

169. As is revealed by a comparison of all the records in this 

communication with Defendant Lunn’s statements alleged above in his 

communication with Defendant Thompson, Defendant Pickering 

However, 

Plaintiff has good grounds to believe and does allege that Defendant Pickering 

 Defendant Lunn or Defendant Thompson 

 Defendant 

Pickering sold May Contracts from 1 p.m. Chicago time to 1:30 pm. 

170. Some of these conversations include the following: 

a) [Henry Lunn]: 

 Connor Younger Fresh:

Device owner Lunn: Elliot Pickering: 

b) Connor Younger

Lunn 

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171. Also pursuant to their combination and agreement, Defendants Paul 

Commins and Demetriou engaged in various conversations to keep one another 

apprised of their positions and intentions via texts on WhatsApp. Among other 

things, they compared their trading positions and confirmed their mutual intentions 

to sell May Contracts outright. 

a. Defendant Commins tells 

Defendant Demetriou to

which Demetriou responds

b. Defendant Demetriou asks 

Defendant Commin

Defendant Commins

responds to Mr. Demetriou. 

c. Defendant Demetriou 

responds 

172. Plaintiff has good grounds to believe and does allege that Defendants 

Paul Commins and Defendant Demetriou confirmed to one another that the other 

Vega Trading Defendants were engaged in the same pattern of placing cumulative 

net selling pressure into the May Contract and diverting buying pressure away 

from the May Contract and into the TAS market. 

173. Defendant Demetriou 

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Defendant Commins responds 

174. The communications between Defendant Commins and Demetrious 

also indicate Defendants’ mutual knowledge of their concerted diversion of buying 

pressure away from the May Contract and into TAS contracts. 

 

a. Defendant Commins 

Defendant Demitriou 

b. Defendant Commins 

s 

Defendant Commins’ 

c. Defendant Commins 

d. Defendant Commins 

Both Defendant Commins and Defendant 

Demetriou, 

e. Defendant Demetriou 

 Defendant Commins 

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Demetriou’s 

175. Defendants Roase 

and Demetriou (or Defendants Roase and Commins) 

Defendant Roase’ 

 Defendant Demetriou and Commins, and Defendant Demetriou’s 

 Defendant Commins. 

176.

 Defendant Roase 

 

177.

 Defendant Roase (Dog) and Defendant Demetriou. 

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178.

Defendant Henry Lunn stated 

 

Defendant Lunn 

179.

 Defendant George Commins 

180. The Commins Defendants’ 

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181.

182.

 

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183.

 Adrian Spires 

[Henry Lunn] 

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 Spires 

 [Henry Lunn], 

 

184.

 Adrian Spires 

 (Demetriou and 

roase) 

[Paul Commins]; 

 [Demetriou]; [Roase]; [George Commins]; 

 [Lunn]; [Younger]; [Thompson]; 

[Pickering]; [

Trader 7 

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185. Adrian Spires Paul 

Commins 

 

186. Adrian Spires 

(Defendant Paul Commins) 

(Defendants Aristos Demetriou and Christopher 

Roase). (Defendants Aristos 

Demetriou, Christopher Roase, and Henry Lunn), 

[Defendant Henry Lunn] 

 [Defendant George Commins] 

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187. Henry Lunn 

Adrian Spires 

 

188. Henry Lunn

Adrian Spires 

 

189. Paul Commins 

 Adrian Spires 

 

190. Commins’ 

[Defendants Aristos Demetriou and Christopher Roase]. Defendants Aristos 

Demetriou and Christopher Roase 

Paul 

Commins 

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191. George 

Commins Aristos Demetriou 

 Adrian 

Spires 

 

192.

 Adrian Spires 

 

 

 

193. Adrian Spires 

Trader 7 Trader 7 Trader 7

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194. Adrian Spires 

 Paul Commins 

 

G. The ICE WTI Crude Oil Futures Contract Price Is Explicitly 

Determined By The Price of the NYMEX WTI Crude Oil Futures 

Contract and Numerous Vega Trading Defendants Profited on the ICE 

Due to Artificially Depressing the May Contract Price on the NYMEX

195. The Defendants had an additional motivation to intentionally cause 

(and they did cause) artificially depressed prices of the May Contract. This is 

because the closing price of the May 2020 NYMEX WTI crude oil futures contract 

on April 20, 2020 determined the settlement price of the May Contract that expired 

on April 20, 2020. 

196. The Intercontinental Exchange (“ICE”) offers trading in effectively 

the same WTI crude oil futures contracts as the NYMEX (i.e., representing 1,000 

barrels of WTI crude oil) with one important difference. 

197. Unlike NYMEX WTI futures contracts, which may be settled by 

physical delivery with trading terminating three business days prior to the 25th 

calendar day of the month prior to the contract month, trading in ICE WTI futures 

contracts terminate on the fourth business day prior to the 25th calendar day of the 

month by “cash settlement,” not physical delivery. 

198. More specifically, ICE WTI futures contracts cash settle to the

penultimate settlement price of the corresponding NYMEX WTI crude oil futures 

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contract. For example, on April 20, 2020, the May Contract cash settled to the 

settlement price of the May 2020 NYMEX WTI crude oil futures contract on April 

20, 2020 (i.e., negative $37.63). 

199. On April 20, 2020, the total volume of May Contracts traded was

approximately 20,789 contracts. At the end of trading on April 20, 2020, a total of 

approximately 23,241 May Contracts remained open and thereby were cash settled 

to the settlement price of the May Contract on April 20, 2020 (i.e., negative 

$37.63). 

200. On April 20, 2020, numerous Vega Trading Defendants engaged in a 

manipulative trading strategy on the ICE that was virtually identical to the 

manipulative trading strategy employed by the Vega Trading Defendants on the 

NYMEX (see ¶¶138-139 above): selling May Contracts and buying May Contracts 

via TAS. See ¶¶203 below. 

201. Because the settlement price of the May Contract on April 20, 2020 

would be, by its express terms, determined by the closing price of the May 2020 

NYMEX WTI futures contract on April 20, 2020 (see ¶¶ 198-99 above), the Vega 

Trading Defendants’ artificial suppression of the May 2020 NYMEX WTI futures 

price alleged herein necessarily resulted in an artificially depressed price of the 

May Contract. 

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202. On April 20, 2020, each of the below Vega Trading Defendants 

purchased May Contracts via TAS and sold May Contracts in approximately the 

amounts set forth below. 

 

a. Defendant Aristos Demetriou

 Defendant 

Demetriou

b. Defendant Henry Lunn

 Defendant Lunn

c. Defendant Christopher Roase

 Defendant 

Roase 

d.

e.

f.

Trader 10 Trader 10

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g.

h.

F. Vega Also Made Its Sales In An Aggressive Manner. 

203. Another means that may be used to depress prices is to make sales in 

an aggressive manner. 

204. Thus, when an “aggressor” sale is executed, it “pulls liquidity out of 

the order book” by “removing resting” bid or bids to purchase contracts. In the 

context of the imbalance of sell orders over buy orders on April 20, the more that 

the bids were pulled out of the order book by executions, the closer that the sell 

orders were to “blitzing” through the orders and causing a rapid decline in prices.

205. Plaintiff has good grounds to believe and does allege that considerably 

more than one half of Vega’s sales were “aggressor” sales. Plaintiff has good 

grounds to believe that discovery will reveal that up to 90% or more of Vega’s 

sales were aggressor sales. Plaintiff’s grounds for these allegations include the 

following. 

206.

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207.

208. Fourth, making “aggressive” sales is consistent with the Vega 

Defendants conduct otherwise alleged herein, including at ¶¶42, 44, 46, 48, 50, 52-

53, 55-59, 112, 146, 154-61, 163-64, 204, 209. 

NEW ALLEGATIONS MADE PURSUANT TO THE ORDER 

I. The Extensive Interconnections, And Formal Contract Among Vega,

 And The Vega Trading Defendants. 

209. Vega’s contract governing its relations with the Vega Trading 

Defendants was an agreement made among (a) Vega, (b) 

 and (c) the Vega Trading Defendants. See ¶¶239-243 below. 

A. The Extensive Interconnections. 

1. The Profit Interests Of Defendants Vega And Spires In . 

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210. Until April 1, 2021, 

was owned 25% by Defendant Paul Commins, 25% by 

 and 50% by who was another trader and 

FCA approved representative of Starmark.12 ¶123. Defendant Commins was 

listed as an office manager and director of the company. 

211. On April 1, 2021, filing with the Companies House 

disclosed for the first time that Adrian Spires was also a person with a 

significant interest and, in fact, control of . The filing disclosed that 

Spires “holds, directly or indirectly, 75% or more of the voting rights in the 

company”, and that were removed 

as directors of Based on this filing, Plaintiff alleges that, from some 

point prior to or as of April 1, 2021 forward, Spires owned a (substantial) 

share of the equity and held a (substantial) share of the voting rights of 

212. On March 1, 2022, was dissolved pursuant to an application cosigned by Defendants Spires and Commins, and no further information was 

provided. 

213. As alleged below (¶¶214-223), 

Defendant Spires’ 

12 See 

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Defendant Spires 

 

214.

 

Defendants Thompson and Sutton. 

Thompson’s 

 

215. Defendant Thompson’s 

Matt Thompson and Henry Lunn 

 

 

defendant Elliot Pickering

 

13 VEGA M1SH 000042676

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Defendant Lunn 

[Emphasis added] See ¶167 above. 

216.

Defendant Sutton, Mr. Sutton 

George Commins 

 See ¶¶328-333 below. As a result of their

consulting with one another in their trading of the May Contract, Defendant 

Sutton’s trading had an extraordinarily high minute to minute correlation with 

Defendant George Commins’ positions of .99. See ¶319 below. And Defendant 

Sutton’s trading also had high correlations of .988 to .951 with the trading of 

Defendants Younger, Pickering, and Lunn. Id. 

217. As previously alleged, Defendant Thompson made approximately 

 and Defendant Sutton made approximately from their 

manipulative trades on April 20th. 

 Defendant Thompson Defendant Sutton 

 Defendants Thompson and Sutton 

218.

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 Thompson and 

Sutton 

 Defendants Thompson and Sutton 

 See ¶218. 

220. Thompson-Sutton 

 Thompson and Sutton 

 See ¶218. 

221.

 Thompson-Sutton 

 See ¶218. 

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222.

 Spires 

223.

2. The Formation Of Vega. 

a. During 2015 And 2016, The United Kingdom Announces And 

Implements Enhanced Prohibitions Of Manipulation 

224. By as early as May 11, 2015, the U.K.’s Financial Conduct Authority 

published its policy proposals and handbook of rules and guidance to support the 

implementation of the new European Market Abuse Regulation regime, to apply 

from July 3, 2016. FCA consults on Market Abuse Regulation policy proposals 

and Handbook changes, FCA Press Release (May 11, 2015), at 

https://www.fca.org.uk/news/press-releases/fca-consults-market-abuse-regulationpolicy-proposals-and-handbook-changes; see FCA’s website Market Abuse 

Regulation, at https://www.fca.org.uk/markets/market-abuse/regulation, hyperlink 

“EU Market Abuse Regulation” (Regulation (EU) No. 596/2014 of the European 

Parliament and of the Council of April 16, 2014 on market abuse (market abuse 

regulation) and repealing Directive 2003/6/EC of the European Parliament and of 

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the Council and Commission Directives 2003/124/EC, 2003/125/EC and 

2004/72/EC) (last visited Apr. 27, 2022). 

225. By December 17, 2015, the European Union supplemented the EU 

Market Abuse Regulation. See E.U. Commission Delegated Regulation (EU) 

2016/522 (applicable from July 3, 2016), at 

https://www.fca.org.uk/markets/market-abuse/regulation, hyperlink “Delegated 

Regulation 2016/522” (last visited Apr. 27, 2022). 

226. Effective July 3, 2016, the EU Market Abuse Regulation was 

automatically applicable in the UK under UK and EU law without the need for any 

domestic implementing legislation as the UK was a member of the EU at the time 

of implementation, and the UK amended its Financial Services and Market Act 

2000 to give effect to and make it compatible with the EU Market Abuse 

Regulation. Financial Services and Market Act 2000 (Market Abuse) Regulations 

2016, Part 1.1 (Statutory Instruments, 2016 No. 680) (“UK MAR”). See Market 

Abuse (Amendment) (EU Exit) Regulations 2019, UK Statutory Instruments (2019 

No. 310) (substantially retaining EU Market Abuse Regulation following the end 

of the Brexit transition period, pursuant to the European Union (Withdrawal Act 

2018), available at https://www.legislation.gov.uk/uksi/2019/310/contents/made 

(last visited April 28, 2022). 

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227. For purposes of Article 12(1)(a) of the UK MAR, which prohibits

manipulation, the UK MAR explicitly sets forth non-exhaustive indicators of 

manipulative trading, effective July 3, 2016. UK MAR, Annex I 

(https://www.fca.org.uk/markets/market-abuse/regulation#revisions, at hyperlink 

“Market Abuse Regulation (MAR)”) (“UK MAR, Annex I”). The indications 

include: 

(a) the extent to which orders to trade given or transactions undertaken 

represent a significant proportion of the daily volume of transactions in the 

relevant financial instrument ..., in particular when those activities lead to a 

significant change in their prices; 

(b) the extent to which orders to trade given or transactions undertaken by 

persons with a significant buying or selling position in a financial 

instrument..., lead to significant changes in the price of that financial 

instrument, related spot commodity contract, or auctioned product based on 

emission allowances; 

**** 

(e) the extent to which orders to trade given or transactions undertaken are 

concentrated within a short time span in the trading session and lead to a 

price change which is subsequently reversed; 

**** 

(g) the extent to which orders to trade are given or transactions are 

undertaken at or around a specific time when reference prices, settlement 

prices and valuations are calculated and lead to price changes which have an 

effect on such prices and valuations. 

UK MAR, Annex I. 

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b. These Enhanced Protections Against Manipulation Created 

Greater Financial And Legal Risks For Firms Which Carried 

Accounts For Manipulators. 

228. After the announcements in 2015 about the increased regulations

against manipulations and market abuses, it was clear that there would be greater 

legal and financial risks for registered persons to hold the accounts of 

manipulators, including persons who manipulated prices at or around the time of 

the determination of the TAS. 

229. These legal and financial risks created incentives to form and opened 

opportunities for persons to form trading firms that could assume the substantial 

legal and financial risk of working with persons who engaged in TAS 

manipulations. Such firms could seek to create a series of norms, trading 

procedures, and compliance (or lack thereof) that facilitated and would help defend 

against charges of TAS manipulations. 

230. In the foregoing context, Vega was incorporated on May 13, 2016, 

with Anthony Gibson as its sole shareholder. See ¶34. 

c. Vega’s Apparent Founder, Anthony Gibson, Is A Business 

Partner With Defendant Commins, Including In 

231. Anthony Gibson and Defendant Paul Commins are or have been 

business partners in various ventures. 

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232. These include, without limitation, 

 and 

 

233. On November 9, 2018, Commins, Gibson and Demetriou incorporated

 as a private limited company 

. According to Companies House records, Demetriou resigned as 

Director on October 7, 2019 and was replaced the same day by Elliott Pickering, 

identified as “Derivatives Trader.” Pickering resigned as Director on May 7, 2020. 

All four owned significant shares in during their directorships, with Commins 

and Gibson still continuing as Directors of , which has an 

active company status with the latest confirmation statement filed on November 

18, 2021. 

234. Defendant Spires worked at and knew Defendant 

Commins while at during 2007 and later. According to the 

Businessweek article “The Essex Boys: How Nine Traders Hit a gusher With 

Negative Oil,” Commins did know Spires while Commins was running “an off-site 

offshoot of Tower Trading Group,” and when Spires and Gaunt left to “start their 

own outfit,” Commins and his team of traders joined him. 

235. It was also Commins’ partner, Anthony Gibson who signed on behalf 

of Vega the agreement with GH Financials alleged below. 

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d. Vega’s High Turnover Of Four Owners In Three Years Before 

Spires Becomes Sole Shareholder. 

236. As previously alleged, Vega had four different owners within three 

years. See ¶34. By February 3, 2020, Defendant Spires was the sole owner of 

Defendant Vega. 

237. Between October 26, 2017 and August 13, 2019, Vega was 

registered with the United Kingdom Financial Control Authority as an 

Appointed Representative of Starmark. 

B. The Written Agreement Between And Among Vega, , And 

The Vega Trading Defendants. 

238. In Autumn 2017 and thereafter, a 

 (“Agreement”) was made between and among 

239. Pursuant to this Agreement

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240.

 

241.

242.

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C. In Its “Market Facing” Agreement With GH Financials, Vega Expressly 

Agreed That It Was The Principal For Each Trade By A Vega Trading 

Defendant And That The Vega Trading Defendants Were Acting As 

Vega’s “Agent” Or Otherwise Acting For Or On Behalf Of Vega. 

243. GH Financials (see ¶65 above) was a clearing member of the 

CME. Pursuant to a “GH FINANCIALS LIMITED TERMS OF BUSINESS 

FOR EXCHANGE TRADED FUTURES AND OPTIONS BUSINESS” 

(“TOB”) (Version 15.1) dated July 12, 2016, and signed by Anthony Ross 

Gibson on behalf of Vega Capital London Ltd., Vega agreed in entering its 

relationship with GH Financials that: 

TOB ¶27 (f). 

244. Vega Expressly Agreed That Trades In Its Accounts Would Be 

Made On Vega’s Behalf By Authorized Persons. Pursuant to Vega’s agreement 

with GH Financials, only of Vega were permitted to perform 

acts on behalf of Vega. 

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102 

 

TOB ¶9 [emphasis added]. 

245. Plaintiff alleges that an under ¶9 of Vega’s Agreement with GH 

Financials quoted above, included the placing of , and the holding of 

orders that were as trades. 

246. Each Vega Trading Defendant typically placed “orders” for its subaccount which were “executed” by GH Financials. 

247. As such, pursuant to Vega’s TOB with GH Financials, ¶9, each Vega 

Trading Defendant was acting either as Vega’s or 

had otherwise been granted by Vega to of Vega to 

enter trades, or had otherwise been granted authority by Vega in its trades. 

248. Plaintiff further alleges that, pursuant to TOB ¶9, Vega was the 

 for all trades made by each Vega Trading Defendant.

249. Vega and GH Financials also entered a “Clearing Module” on July 12, 

2016. They later entered, on or about November 16, 2017, an updated Terms of 

Business for Exchange Traded Futures and Options Business. 

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250. Neither the Clearing Module nor the updated November 16, 2017 

agreement purported to modify or amend the foregoing provisions of the TOB in 

any way. 

251. On the contrary, the 2017 TOB expressly provides and adds to the 

former clause 27(f) (quoted above): 

2017 TOB ¶6(b). 

252. “Applicable Regulations” is defined in ¶5 of the 2017 TOB as 

meaning: 

2017 TOB ¶5. For transactions on the CME, applicable laws include U.S. laws, 

including, but not limited to the laws prohibiting manipulation, and agreements to 

fix and manipulate prices. 

253. When GH Financials terminated its business with Vega after the May 

Contract manipulation on April 20th, GH Financials did not terminate the business 

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only with the Vega Trading Defendants. Instead, GH Financials terminated all 

business with Vega. 

1. Long Before April 20, 2020, Defendants Vega And Spires Well Knew 

That The VTDs Traded In Unison To Manipulate Prices. 

254. The Vega Trading Defendants “regularly” acted in unison to 

make transactions which moved the TAS price at the time of settlement. 

255. For example, in an award-winning article authored by Liam 

Vaughan, Kit Chellel & Benjamin Bain, London Traders Hit $500 Million 

Jackpot When Oil Went Negative, Bloomberg Businessweek (August 4, 

2020) explicitly reported as follows: 

Vega’s jackpot [on April 20, 2020 in the May contract] ...involved about a 

dozen traders aggressively selling oil in unison before the May West Texas 

Intermediate contract settled at 2:30 p.m. in New York...It’s a tactic Vega’s 

traders used regularly, according to another person familiar with the 

firm’s strategy... 

See full copy of article, annexed as Exhibit 2 to this Amended Complaint. 

256. In another award-winning article authored by Liam Vaughan, 

The Essex Boys: How Nine Traders Hit a Gusher With Negative Oil, 

Bloomberg, (December 10, 2020) explicitly reported that 

...trading records and people who worked alongside them [the VTDs] 

indicate they [the VTDs] frequently operated in a similar fashion [to their 

conduct on April 20th in the May Contract], buying or selling in the same 

direction at key moments. 

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See full copy of article, annexed as Exhibit 1 to this Amended Complaint. 

257. The articles won the British Journalism award for Crime and 

Legal Affairs Journalism in 2021. https://pressgazette.co.uk/britishjournalism-awards-winners-2021/

258. The award-winning journalism quoted above reports that 

“trading records”, “people who worked alongside” the Vega Trading 

Defendants, and “a person familiar with the firm’s strategy”, all show or 

indicate that, prior to April 20, 2020, the Vega traders “regularly” or 

“frequently” traded in a similar fashion to their manipulative trading on 

April 20th. Regarding the reference to “trading records” in the award 

winning article quoted above, Vega and Spires also had complete 

knowledge of the trading records of the Vega Trading Defendants. This 

included real time knowledge of what the VTDs were trading and doing. 

Prior to COVID, Vega and Spires had at times worked in the same office 

and “alongside” at least some of the VTDs in the trading arcade. 

259. In fact, Defendants Vega and Spires had access to much more 

than simply the trading records. Based on the allegations set forth below, 

Defendants Vega and Spires had sophisticated detailed analytical tools in 

real time. This enabled Defendants Vega and Spires easily to detect trading 

patterns in real time, as these patterns developed. This included high degrees 

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of correlation of the trading between and among the accounts. Among 

other things: 

Adrian Spires, 

b. Spires, 

c.

 Adrian Spires 

) 

d.

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e.

f.

g.

h.

i.

j. Spires, 

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k.

 

l.

) 

260. Corroborating the award winning journalism based upon the 

multiple sources alleged above, VTD Lunn stated that 

 See ¶179 above. VTD Lunn’s 

261. As of April 20, 2020, Defendants Vega and Spires also had 

handled the VTDs’ trading for Vega and Spires also well knew that 

the Vega Trading Defendants had for years traded together to 

markets by making trades in unison to move prices. 

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2. The Vega Trading Defendants Engaged in Coordinated Trading 

In WTI Crude Oil Futures Contracts A Month Prior to Engaging 

in Substantially Similar But More Extreme Conduct on April 20, 

2020 

262. By March 19, 2020, the penultimate trading day in the April 2020 

NYMEX WTI crude oil futures contract, the trading volume in the April 2020 

contract had been significantly reduced. The low volume (i.e., “thin” market) 

made the April 2020 contract susceptible to manipulation by “ammo” trading. 

263. The average trading volume in the April 2020 contract for the twenty 

(20) trading days preceding March 19, 2020 was approximately 881,814 contracts. 

The trading volume in the April 2020 contract on March 19, 2020 was 

approximately 136,722 contracts, an 84.5% decrease in the average volume for the 

preceding twenty (20) trading days. 

264. On March 19, 2020, the Vega Trading Defendants sold approximately 

April 2020 contracts, purchased approximately May 2020 contracts, 

purchased approximately April 2020 contracts via TAS and sold 

approximately May 2020 contracts via TAS. 

.

14 

a. Defendant Demetriou

14 Defendants Biagioni, Sutton and did not trade NYMEX WTI futures on March 

19, 2020. 

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b. Defendant Roase 

c. Defendant Pickering 

d. Defendant Paul Commins

e. Defendant Matthew Thompson

f. Defendant Younger

g. Defendant Lunn 

h. Defendant George Commins

15 Defendant Demetriou also sold May 2020 contracts and purchased May 2020 

contracts via TAS. 

16 Defendant Pickering also purchased April 2020 contracts and sold May 2020 

contracts. 

17 Defendant Younger also purchased April 2020 contracts, sold April 2020 contracts 

via TAS, sold May 2020 contracts and purchased May 2020 contracts via TAS. 

18 Defendant Lunn also sold May 2020 contracts. 

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265. The foregoing short April and long May “spread” positions, along 

with the corresponding TAS orders to buy the April contract and sell May contract 

at their respective settlement prices, gave each of the above Vega Trading 

Defendants an incentive to depress the price of the April contract relative to the 

price of the May contract. 

266.

. 

267.

 

268. Based upon Plaintiff’s interpretations of 

 and CME market depth data 

for March 19, 2020, Plaintiff alleges as follows with respect to the intra-day 

trading of the Vega Trading Defendants on March 19, 2020. 

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269. During the final hour of trading on March 19, 2020 (i.e., 12:30 to 1:30 

pm central time) the Vega Trading Defendants sold a total of approximately 

April 2020 contracts.19 That is, the Vega Trading Defendants waited until late in 

the trading day and compressed more than of their total April 2020 contract 

sales during the final hour of trading. During the final hour of trading, the price of 

the April-May spread decreased from approximately negative 53 cents at 12:30 pm 

to approximately negative 69 cents at 1:30 pm. During the final hour of trading, 

the Vega Trading Defendants sold the April 2020 contract in the following 

volumes. 

a. Defendant Demetriou 

b. Defendant Pickering 

c. Defendant Younger

d. Defendant Roase 

e. Defendant Matthew Thompson 

f. Defendant Lunn 

g. Defendant Paul Commins 

h. Defendant George Commins 

 

19 The Vega Trading Defendants also purchased April 2020 contracts during the final hour 

of trading. 

20 Defendant Pickering also purchased April 2020 contracts during the final hour of trading. 

21 Defendant Younger also purchased April 2020 contracts during the final hour of trading. 

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270. During the final thirty (30) minutes of trading on March 19, 2020 (i.e., 

1:00 to 1:30 pm central time) the Vega Trading Defendants sold a total of 

approximately April 2020 contracts.22 That is, the Vega Trading Defendants 

waited until late in the trading day and compressed more than of their total 

April 2020 contract sales during the final thirty (30) minutes of trading. During the 

final thirty (30) minutes of trading, the price of the April-May spread decreased 

from approximately negative 49 cents at 1:00 pm to approximately negative 69 

cents at 1:30 pm. During the final thirty (30) minutes of trading, the Vega Trading 

Defendants sold the April 2020 contract in the following volumes. 

a. Defendant Pickering 

b. Defendant Demetriou 

c. Defendant Younger 

d. Defendant Lunn 

e. Defendant Matthew Thompson 

 

f. Defendant Paul Commins 

g. Defendant George Commins 

22 The Vega Trading Defendants also purchased April 2020 contracts during the final thirty 

minutes of trading. 

23 Defendant Pickering also purchased April 2020 contract. 

24 Defendant Younger also purchased April 2020 contracts. 

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271. During the final two (2) minutes of trading on March 19, 2020 (i.e., 

1:28 to 1:30 pm central time) the Vega Trading Defendants sold a total of 

approximately April 2020 contracts. During the final two (2) minutes of 

trading, the price of the April-May spread decreased from approximately negative 

65 cents at 1:28 pm to approximately negative 69 cents at 1:30 pm. During the 

final two (2) minutes of trading, the Vega Trading Defendants sold the April 2020 

contract in the following volumes. 

a. Defendant Demetriou 

b. Defendant Paul Commins 

c. Defendant Pickering 

 

d. Defendant Matthew Thompson 

e. Defendant George Commins 

272. Based on time and sales information in the CME market depth data 

, the Vega Trading 

Defendants’ (a) sales of approximately April 2020 contracts during the final 

hour of trading constituted approximately of the volume of April 2020 

contracts during that time period; (b) sales of approximately April 2020 

contracts during the final thirty (30) minutes of trading constituted approximately 

 of the volume of April 2020 contracts during that time period; and (c) sales of 

approximately April 2020 contracts during the last two (2) minutes of trading 

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constituted approximately of the volume of April 2020 contracts during that 

time period. 

273. At the close of trading on March 19, 2020, the April-May spread

settled at negative 69 cents. The closing spread price of negative 69 cents on 

March 19 was an all-time low for the spread price of the April-May 2020 contracts 

and was more than four standard deviations lower than the mean spread over the 

prior year of trading. 

274. At the close of the next trading day on March 20, 2020, the April-May 

spread settled at negative 20 cents. Thus, on March 20, 2020, after Vega’s trading 

on March 19 had ceased, the spread price rebounded substantially by 49 cents. 

275. In total, the Vega Trading Defendants generated net profits of 

approximately in connection with their trading of April and May 2020 

contracts on March 19, 2020: 

a. Defendant Roase 

b. Defendant Demetriou

c. Defendant Paul Commins

d. Defendant Pickering 

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e. Defendant Thompson

f. Defendant Younger

g. Defendant Lunn 

h. Defendant George Commins

3. Based on the Vega Trading Defendants’ Activities on March 19, 2020 

and Other Reasons, Defendants Vega Capital and Spires Knew That

The Vega Trading Defendants Were Engaged in Manipulative Trading 

And Affirmatively Took Steps To Facilitate The Manipulation. 

276. The potential for abuse of TAS trading in order to affect the price of a 

commodity futures contract is well known. The Commodity Futures Trading 

Commission (“CFTC”) has brought multiple cases involving TAS trading, 

including TAS trading in the WTI crude oil futures market.

277. In 2016 new regulations were passed in the U.K. that included a nonexhaustive list of manipulative trading indicators. Such indicators included: (a) 

significant buying or selling of a financial instrument that leads to significant 

changes in the price of that financial instrument; (b) transactions concentrated 

within a short time span in the trading session and lead to a price change which is 

subsequently reversed; and (c) transactions undertaken at or around the time when 

settlement prices are calculated which have an effect on such prices. All three of 

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these indicators were present in respect of the Vega Trading Defendants’ trading 

activity on March 19, 2020. See ¶¶224-227 above.

278. As part of Vega agreement with GH Financials, Vega represented, 

warranted and agreed, among other things, that 

 

279.

280. As part of its agreement with GH Financials, Vega agreed to 

 As part of Vega’s agreement with 

the Vega Trading Defendants, Vega agreed to GHF 

TOB Annex 3, Section 3

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281.

 Spires 

 

282. According to Bloomberg’s award-winning reporting, a person familiar 

with Vega’s strategy stated that Vega’s traders “regularly” traded in unison. 

283. Far beyond being merely “familiar” with the Vega Trading 

Defendants’ strategy, Defendants Vega and Spires had real time access to all 

trading in Vega’s accounts and received daily statements of all trading in Vega’s 

accounts, 

 

284. A review of Vega’s trading on March 19, 2020, just a month before 

April 20, would have revealed the following “red flags” to Defendants Vega and 

Spires: (a) each of the eight Vega Trading Defendants that traded NYMEX WTI 

crude oil futures traded in the exact same direction in both the April and May 

contracts; (b) each of the eight traders that traded NYMEX WTI crude oil futures 

also used TAS orders in the same direction for both the April and May contracts; 

(c) the traders traded a significant volume of contracts in the April contract (more 

than contracts or more than barrels of 

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oil), which was set to expire the following day; (d) a substantial volume of 

transactions by the Vega Trading Defendants were concentrated near the end of 

trading on March 19, 2020; and (e) the April-May spread price moved in the 

direction of Vega’s trading on March 19, 2020 and then reversed on the next 

trading day on March 20, 2020. See above. 

285. Despite the coordinated ammo trading in the April 2020 contract on 

March 19, which, like the May 2020 contract on April 20, was set to expire the 

following day, Defendants Vega and Spires did not take steps to prevent the Vega 

Trading Defendants from engaging in substantially similar manipulative conduct 

on a much larger scale on April 20, 2020. 

286. Going well beyond the trading on March 19, on April 20, twelve Vega 

Trading Defendants, not eight, engaged in coordinated trading and the Vega 

Trading Defendants their volume of trades on April 20 (more than 

contracts on April 20 in the front month contract versus more than contracts 

on March 19 in the front month contract). 

287.

 that Defendants Vega and Spires revoked the Vega 

Trading Defendants’ access to Vega’s trading accounts. 

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4. The VTDs Stalked Futures Contracts To Determine Those Most 

Vulnerable To Manipulation, And Then Blitz The Market By 

Making Trades In Unison To Move Prices. 

288. Plaintiff has good grounds to believe and does allege that when

Defendants Lunn stated shortly after the close on April 20th that 

, his reference to referred to the Vega Trading Defendants; 

his use of the word referred to the VTDs’ extensive ammo trades to 

drive down prices between 1pm and 1:30; and his reference to referred 

to the May Contract and, specifically, the last 30 minutes of trading therein. 

289. The VTDs’ of futures contracts to manipulate the 

final settlement prices or prices at other key times, was most likely to be 

successful in markets which were thinly traded and had less new entrants 

into the market. In such market conditions, the VTDs’ chances to trade in 

unison to successfully blitz the market and manipulate prices were much 

higher. 

290. The VTDs often had greater volumes of trades in contracts 

which, like the April WTI contract and the May WTI contract, were near the 

end of trading and less likely to have new entrants. Such contracts were 

more likely to have lower trade volume than earlier during the life of the 

contract when there were more new entrants into the market. 

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291. In addition to the April 2020 and May 2020 WTI contracts, the 

VTDs traded significant volumes of contracts in other contracts which were 

near expiration and likely to have less new entrants. 

292. For one example, seven of the VTDs (Defendants Paul 

Commins, Demetriou, Roase, Lunn, Younger, and traded 

 April ICE gasoil futures contracts on March 25, 2020 when the 

volume in that contract was approximately 1/3 of its trailing 30 day average. 

5. Defendants Vega And Spires Actively Facilitated The April 20th

Manipulation, Profited Therefrom, And Specifically Intended 

That The Trades Which Vega Was Making In The May Contract 

Would Manipulatively Depress May Contract Prices 

293. Defendant Spires worked in and was 

See ¶¶ 114-117. 

294. According to a former compliance person at the IPE, the IPE should 

have had restrictions relating to TAS which made TAS manipulation on the IPE 

more difficult. See Oil Bonanza at U.K. Firm Casts Light on Price-Blind Trades, 

Liam Vaughan and Benjamin Bain (August 7, 2020), 

https://www.bloomberg.com/news/articles/2020-08-07/oil-bonanza-at-u-k-firmcasts-spotlight-on-price-blind-trades. After leaving the IPE, such compliance 

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person learned that the wrongdoing on the IPE in TAS manipulation was “blatant”. 

Id. 

295. In general, there are two types of compliance people. The first type 

consists of persons who seek to enforce compliance with the rules. The second 

type seek to facilitate the violation of the rules (here, manipulation) but use their 

compliance knowledge simultaneously to try to avoid adverse consequences from 

such violation. 

296. On and well before April 20th, the work of Defendants Spires and 

Vega in fulfilling their duties to achieve compliance with the rules and prevent 

manipulation, greatly facilitated manipulation and sought to avoid the adverse 

consequences from manipulation. And Defendant Spires and Vega consistently 

did not seek to prevent manipulation. 

297. With full knowledge of what had happened on the penultimate trading 

day of the prior expiring WTI contract (that is, the April Contract on March 19th, 

see above), Defendants Vega and Spires facilitated the manipulation of May 

Contract on its penultimate day of trading. 

298. Spires 

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299. Spires 

300. Spires

301. Spires

302. Spires

 

303. Spires

304. Spires 

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305.

 Spires 

Spires 

 

306. But instead of sending emails or other written communications 

demanding explanations from the VTDs about what they were doing, Defendants 

Vega and Spires did nothing to stop the manipulation. 

307. On the contrary, consistent with the long train of facts beginning with 

the creation of Vega after more restrictive prohibitions of manipulation (including 

TAS manipulation) had been announced, the only affirmative actions in which 

Defendants Vega and Spires had engaged were those which facilitated the 

manipulation, e.g., . In 

addition to failing to ask any questions of anyone, Defendants Vega and Spires did 

not, for example, restrain the amounts of trades that the VTDs could make. Nor did 

Vega and Spires take any other steps to avoid manipulation. 

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308. Instead, Defendants Vega and Spires continued to allow the 

manipulation to succeed 

 

309. Plaintiff has good grounds to believe and does allege that the specific 

intention of Defendants Vega and Spires on April 20th was to facilitate the 

manipulation by the VTDs of the May Contract. Defendants Vega and Spires had a 

substantial financial motivation for doing so based on their profit shares of 

Defendants Thompson and Sutton. Defendants Spires and Vega could see in real 

time the large short positions that Defendants Thompson and Sutton were 

developing in the May Contract. Plaintiff has good grounds to believe and does 

allege that Defendants Vega and Spires had other financial reasons to facilitate the 

manipulation. 

310. In the vacuum of compliance conduct by Defendants Vega and Spires, 

GH Financials began to send trading alerts and ask questions on the afternoon of 

April 20th. Defendants Vega and Spires demonstrated no initiative or efforts 

additional to GH Financials’ questions to uncover a manipulation by the VTDs. 

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Instead, Defendants Vega and Spires merely acted as a vessel to answer the 

questions put by GH Financials. 

311. But as the GH Financials questions were beginning, Defendants 

Spires sought to avoid detection of the manipulation and minimize the adverse 

consequences therefrom by telling Defendant Lunn (the ebullient Defendant who 

said that, after years of training, the VTDs had 

 Specifically,

Defendant Lunn stated to and others on the morning of April 21st: 

Henry: 

Henry “Normal”: 

[emphasis added] Vega_Mish_00021-25. Defendant positions in the 

May Contract had an extremely high minute to minute correlation with other 

VTDs, e.g., .965 (Defendant Lunn); .965 (Defendant Roase); .960 (Defendant 

Demetriou) and .946 (Defendant Pickering). 

312. Both “Henry” and “Henry Normal” are identified as being Defendant 

Henry Lunn in the Vega letter to the CME. Vega_MISH_000042691. Plaintiff has 

good grounds to believe and does allege that the explanation for the difference in 

display names may be that Defendant Lunn switched electronic devices; in any 

event, both Henry and Henry Normal signify that it is Henry Lunn talking. 

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313. Plaintiff has good grounds to believe and does allege as follows. First, 

“Adrian” as used by Defendant Lunn above, refers to Adrian Spires. Plaintiff 

alleges that it was Adrian Spires who called Defendant Lunn and told him not to 

tell 

a. One basis for Plaintiff’s foregoing belief is that no , other than 

Adrian Spires, appears in any of the scores of names included in the 

production to Plaintiff. 

b. Another basis is the long train of conduct by Defendants Spires and Vega 

alleged below, which further supports Plaintiff’s allegations that 

Defendant Spires and Vega knew about and participated in Defendants’ 

manipulations. 

314. Based on the foregoing, Defendant Spires’ statement to Defendant 

Lunn on April 20th, constitutes a further 

manipulative act intended to minimize the likelihood of detection of the VTDs 

manipulation on April 20th, and avoid the adverse consequences of such detection. 

6. Defendant 

315. (a) First, Defendant admits tha

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(b) Second, Defendant expressly admits 

VEGA_MISH_000042650. includes Defendant Spires and others at 

Vega. 

316. Defendant foregoing admitted 

317. That Defendant did, during this excellent opportunity to 

conspire, actually reach an agreement with the VTDs, is strongly corroborated by 

the following. 

318. Defendant May Contract trading has an extremely high minute 

to minute correlation of .989 to Defendant George Commins minute to minute 

positions. 

319. Defendant minute to minute correlation on April 20th with 

Defendant Sutton’s minute to minute positions is an extraordinarily high .984. 

320. Defendant minute to minute correlation on April 20th with 

Defendant Younger’s minute to minute positions is an extraordinarily high .975. 

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321. Defendant minute to minute correlation on April 20th with 

Defendant Pickering’s minute to minute positions is an extraordinarily high .971 

322. Defendant minute to minute correlation on April 20th with 

Defendant Lunn’s minute to minute positions is a very high .944. 

323. The foregoing extremely high correlations are very contrary to 

independent conduct. They are extremely consistent with an agreement between 

 and the VTDs to depress May Contract prices. 

324. Also, Defendant also made increasing amounts of aggressor 

sales in the May Contract beginning at 11am. 

325. Additionally, Defendant made aggressor, uneconomic “ammo” 

sales between 1 and 1:30pm including while the CME was entering stop trading 

orders to attempt to maintain orderly May Contract trading. 

326. By joining other VTDs in making uneconomic aggressor “ammo” 

sales at increasingly lower prices between 1 and 1:30pm, Defendant and the 

other VTDs overcame the CME’s orderly-market trading halts, and greatly 

depressed May Contract prices. 

327. Because Defendant trading pattern manipulatively sought to 

depress prices on a public market, and manipulation of a public market is more 

likely to succeed through an agreement with others than by one’s own trading, it is 

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extremely plausible that Defendant and other VTDs were trading on April 

20th pursuant to an agreement to depress prices. 

7. Defendant Paul Sutton 

328. In addition to the parallel conduct in which Defendant Sutton 

and the other VTDs engaged, Sutton’s communications with other VTDs 

include at least 48 text communications which Sutton initiated with 

Defendant George Commins on April 20, 2020 as they coordinated their 

trading in the May Contract. 

329. As a result of such coordination, Defendant Sutton’s minute to 

minute positions on April 20th in the May Contract has an extraordinarily 

high correlation to Defendant George Commins’ minute to minute positions 

of 99.3%. 

330. Such Defendants’ high degree of coordination of their May 

Contract trading includes, for example, the following communications. 

a. At 3:15 am Chicago time (9:15 am London time) Sutton states 

to Defendant Commins “It’s all about wti now”. 

b. At 9:24 to 9:25 Chicago time, George Commins and Paul 

Sutton 

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331. Defendant Sutton 

Defendant Commins 

 Approximately two minutes after the request, at 12:58pm Chicago 

Time, Defendant Sutton sent Defendants Commins 

Sutton Defendant George Commons 

 

332. Also, Defendant Sutton’s minute by minute positions in the 

May Contract was 94.9% correlated with the overall minute to minute 

positions of Defendants Paul Commins, George Commins, Christopher 

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Roase, Elliott Pickering, Aristos Demetriou, Connor Younger, Henry Lunn, 

and Matthew Rhys Thompson. 

333. The extremely high correlations of Defendant Sutton’s trading 

with that of the other manipulators, combined with the numerous explicit 

communications coordinating his trading with Defendant Commins, is 

highly consistent with an agreement to manipulate May Contract prices and 

directly contrary to independent individual decision making by Defendant 

Sutton. 

CLASS ALLEGATIONS 

334. Plaintiff brings this action on behalf of itself, and all others similarly 

situated, pursuant to Rules 23(a) and 23(b)(3) of the Federal Rules of Civil 

Procedure on behalf of the following Class: 

All persons and entities that purchased and/or sold during the period 

from at least April 20, 2020 through at least April 21, 2020 a May 2020 

light sweet crude oil (WTI) futures contract traded on the NYMEX 

and/or the ICE. Excluded from the Class are Defendants and their 

officers, directors, management, employees, subsidiaries, or affiliates 

and all federal governmental entities.25

335. The Class is so numerous that joinder of all members is impracticable. 

Due to the nature of the commerce involved, the members of the Class are 

25 Plaintiff reserves the right to amend the definition of the Class in the class motion or 

otherwise. 

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geographically dispersed throughout the United States. Plaintiff believes there are 

hundreds of members of the Class. 

336. Common questions of law and fact exist as to all members of the

Class and predominate over any questions solely affecting individual members of 

the Class. Among the questions of law and fact common to the Class are: 

a. Whether Defendants combined, conspired, and agreed to 

manipulate and fix the prices of NYMEX and/or ICE WTI 

crude oil futures contracts in violation of the Sherman Act; 

b. whether Defendants manipulated NYMEX and/or ICE WTI 

crude oil futures contracts in violation of the CEA; 

c. whether such manipulation caused NYMEX and/or ICE WTI 

crude oil futures contracts to be artificial; 

d. whether such manipulation caused cognizable legal injury 

under the CEA; 

e. whether such injury or the extent of such artificiality may be 

established by common, class-wide means, including, for 

example, by regression analysis, econometric formula, or other 

economic tests; 

f. whether Defendants were unjustly enriched to the detriment of 

Plaintiff and the Class; and 

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g. the operative time period and extent of Defendants’ foregoing 

violations. 

337. Plaintiff’s claims are typical of the claims of the other members of the 

Class he seeks to represent. Plaintiff and members of the Class all sustained 

damages arising out of Defendant’s same course of unlawful conduct alleged 

herein. 

338. Plaintiff will fully and adequately protect the interests of all members 

of the Class. Plaintiff has retained counsel experienced in complex commodity 

futures manipulation and antitrust class actions. Plaintiff has no interests that are 

adverse to or in conflict with other members of the Class. 

339. The questions of law and fact common to the members of the Class 

predominate over any questions which may affect only individual members. 

340. A class action is superior to other available methods for the fair and 

efficient adjudication of this controversy since joinder of all class members is 

impracticable. The prosecution of separate actions by individual members of the 

Class would impose heavy burdens upon the courts, and would also create a risk of 

inconsistent or varying adjudications of the questions of law and fact common to 

the Class. A class action, on the other hand, would achieve substantial economies 

of time, effort, and expense, and would assure uniformity of decision with respect 

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to persons similarly situated. It would do so without sacrificing procedural fairness 

or bringing about other undesirable results. 

341. The interest of members of the Class in individually controlling the 

prosecution of separate actions is theoretical rather than practical. The Class has a 

high degree of cohesion, and prosecution of the action through representatives 

would be unobjectionable. Plaintiff anticipates no difficulty in the management of 

this action as a class action. 

INJURY TO PLAINTIFF AND CLASS MEMBERS 

342. During the Class Period, Plaintiff and Class members transacted in 

WTI crude oil futures contracts at artificial prices and were deprived of a lawfully 

operating market. 

343. Further, by reason of the alleged violations of the CEA and Sherman 

Act, Plaintiff and Class members sold at prices that were not what they would have 

paid in the absence of the extensive unlawful conduct alleged herein. As a result, 

Plaintiff and Class members have suffered a legally cognizable injury due to 

Defendants’ alleged violations of the CEA and Sherman Act. 

344. Defendants’ manipulation caused fluctuating amounts of artificiality 

in the prices of NYMEX WTI crude oil futures contracts beginning at least as early 

as April 20, 2020 and continuing until at least until April 21, 2020. 

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345. The specific amounts of actual damages under the CEA and damages 

under the Sherman Act have not yet been determined because such determination 

will require discovery of the conduct of Defendants, the NYMEX, and other nonparties. 

AS AND FOR A FIRST CLAIM 

AGAINST ALL DEFENDANTS 

(Violation of Section 1 of the Sherman Antitrust Act 15 U.S.C. §1 et seq.) 

346. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

347. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants (see ¶¶39-59 above), and John Doe Defendants 1-100 entered 

into and engaged in a combination and conspiracy in an unreasonable and unlawful 

restraint of trade in violation of Section 1 of the Sherman Act Antitrust Act, 15 

U.S.C. §1 et seq. (“Sherman Act”). 

348. Defendants combined, conspired, and agreed to manipulate and fix 

NYMEX WTI crude oil futures prices and ICE WTI crude oil futures prices during 

at least the Class Period. 

349. Defendants’ conspiracy to fix and manipulate prices was spectacularly 

successful and allowed Defendants to greatly profit from their violations of Section 

1 of the Sherman Act. 

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350. Defendants used instrumentalities of interstate commerce and 

adversely affected and restrained trade and commerce through their conspiracy and 

effects on prices. 

351. Defendants’ conspiracy to manipulate and fix the prices of NYMEX 

WTI crude oil futures contracts and ICE WTI crude oil futures contracts deprived 

Plaintiff and members of the Class of the ability to transact in a market free from 

manipulated and fixed prices. 

352. The conspiracy alleged herein is a per se violation of Section 1 of the 

Sherman Act. Alternatively, the conspiracy resulted in substantial anticompetitive 

effects in the NYMEX and ICE WTI crude oil futures markets. There is no 

legitimate business justification for, and no pro-competitive benefit caused by, 

Defendants’ conspiracy and overt acts taken in furtherance thereof. Any ostensible 

pro-competitive benefits are pretextual or could have been achieved by less 

restrictive means. 

353. As a direct, material, and proximate result of Defendants’ violations 

of Section 1 of the Sherman Act, Plaintiff and the Class suffered injury to their 

business and property, including but not limited to transacting at the artificial and 

fixed prices caused by Defendants, within the meaning of Section 4 of the Clayton 

Antitrust Act, 15 US.C. §12 et seq. (“Clayton Act”). 

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354. Plaintiff and the Class seek treble damages for Defendants’ violations 

of Section 1 of the Sherman Act and under Section 4 of the Clayton Act. 

AS AND FOR A SECOND CLAIM 

AGAINST ALL DEFENDANTS 

(Manipulation In Violation Of The Commodity Exchange Act 7 U.S.C. §1 et 

seq.) 

355. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

356. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants, and John Doe Defendants 1-100 manipulated and conspired to 

manipulate the prices of NYMEX WTI crude oil futures contracts and ICE WTI 

crude oil futures contracts in violation of the Commodity Exchange Act, 7 U.S.C. 

§1 et seq. (“CEA”). Defendant Vega Capital having held or otherwise financed the 

manipulative trades alleged herein for each of the Vega Trading Defendants, is 

fully responsible for the manipulation and conspiracy to manipulate alleged herein. 

Defendant Spires, as sole director of Defendant Vega Capital who, again, held or 

otherwise financed the manipulative trades alleged herein, is also fully responsible 

for the manipulation and conspiracy to manipulate alleged herein. 

357. Plaintiff and members of the Class purchased and/or sold one or more 

NYMEX WTI crude oil futures contract and/or ICE WTI crude oil futures contract 

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during the Class Period at artificial prices caused by Defendants and were injured 

as a result of Defendants’ intentional manipulation and conspiracy to manipulate 

the prices of those futures contracts in violation of the CEA, 7 U.S.C. §1 et seq. 

358. In addition to the previously alleged all-time record deviation between 

May Contract prices and June WTI contract prices, there was also an all-time 

record deviation between May Contract prices and the June Brent futures contract 

price. 

359. The spread between the May Contract and the Brent crude June 

futures contract price fell 80 standard deviations on April 20. This occurrence was 

extremely unlikely in a competitive market. But after Vega’s market power was 

removed, the spread between the May Contract and the June Brent contract 

snapped back to almost exactly the same level as it had been on April 17 (-9.32 on 

April 21 and -9.81 on April 17). 

360. Again, there was no fundamental supply and demand explanation for 

these unprecedented deviations in prices of the May Contract from their normal 

benchmark on April 20 followed by their unprecedented snapbacks to normality on 

April 21, 2020. 

361. The deleterious effects of the Vega Defendants’ concerted conduct 

and market power during April 20 were a proximate and substantial cause, as well 

as a contributing factor to the extraordinary widening of spreads on April 20. The 

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removal of Vega’s concerted conduct and market power, was a substantial and 

proximate cause of the snapback in spreads on April 21. The supply-demand 

fundamentals were then again expressed in price levels, as they had been on April 

17. 

362. Defendants’ conduct and trading activity alleged herein constituted a 

manipulation of NYMEX WTI crude oil futures contract prices and ICE WTI 

crude oil futures contract prices in violation of Sections 9(a) and 22(a) of the CEA, 

7 U.S.C. §§ 13(a), 25(a). 

363. As result of Defendants’ unlawful conduct, Plaintiff and members of 

the Class have suffered actual damages and transacted at artificial prices to which 

they would not have been subject but for the unlawful conduct of Defendants as 

alleged herein. 

364. Plaintiff and members of the Class are each entitled to damages for 

Defendants’ violations of the CEA alleged herein. 

AS AND FOR A THIRD CLAIM 

AGAINST ALL DEFENDANTS 

(Principal-Agent Liability In Violation Of The Commodity Exchange Act 7 

U.S.C. §1 et seq.) 

365. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

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366. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants, and John Doe Defendants 1-100 were principals, agents, coventurers and/or guarantors of one another. As agents, co-venturers and/or 

guarantors of one another, the Defendants engaged in a manipulative scheme and 

conspiracy to manipulate prices alleged herein on behalf of one another and with 

one another’s knowledge and authorization. 

367. Under Section 2(a)(1)(B) of the CEA, 7 U.S.C. §2(a)(1)(B), 

Defendants are liable for the acts of their agents. 

368. Plaintiff and members of the Class are each entitled to damages for 

the violations of the CEA alleged herein. 

AS AND FOR A FOURTH CLAIM 

AGAINST ALL DEFENDANTS 

(Aiding and Abetting Liability In Violation Of The Commodity Exchange Act 

D. U.S.C. §1 et seq.) 

369. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

370. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants and John Doe Defendants 1-100 each played their component 

role and each knowingly aided, abetted, counseled, induced, and/or conspired or 

procured the violations of the CEA alleged herein. Defendants knew of the 

manipulative scheme and conspiracy to manipulate alleged herein, intended to help 

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the other Defendants perpetrate such manipulative scheme and conspiracy to 

manipulate and committed one or mor acts in furtherance of such manipulative 

scheme and conspiracy to manipulate. 

371. Each of the Vega Trading Defendants utilized or shared trading 

accounts held in the name of Defendant Vega Capital London, Ltd. Defendant 

Spires is the sole director of Defendant Vega Capital. As the sole director of 

Defendant Vega Capital, the entity that held the trading accounts used to make the 

manipulative trades alleged herein, Defendants Spires and Vega Capital knew of 

the manipulative scheme and conspiracy to manipulate, intended to help the other 

Defendants perpetrate the manipulative scheme and conspiracy to manipulate 

(which generated large profits for the Defendants) and committed one or more acts 

in furtherance of such manipulative scheme and conspiracy to manipulate, 

including by holding or otherwise financing the manipulative positions and/or 

trades alleged herein. 

372. Each of the Vega Trading Defendants aided and abetted the 

manipulative scheme and conspiracy to manipulate including by conspiring to sell 

large volumes of May 2020 NYMEX WTI crude oil futures contracts for the 

purpose of depressing the price of such contract and the price of the May 2020 ICE 

WTI crude oil futures contract. 

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373. Under Section 13 of the CEA, 7 U.S.C. §13c (a), Defendants are 

liable for willfully intending to assist the manipulation. 

374. Plaintiff and members of the Class are each entitled to damages for 

the violations of the CEA alleged herein. 

AS AND FOR A FIFTH CLAIM 

AGAINST ALL DEFENDANTS 

(Manipulation In Violation of the Commodity Exchange Act, 

7 U.S.C. §§1, et seq. and Regulation 180.1(a)) 

375. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

376. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants and John Doe Defendants 1-100 intentionally or recklessly, 

used or employed, attempted to use or employ or conspired to use or employ, one 

or more manipulative devices, schemes or artifices to defraud and/or engaged, 

attempted to engage, or conspired to engage, in one or more acts, practices, or 

courses of business, which operated or would operate as a fraud or deceit in 

violation of the 6(c)(1) of the CEA, as amended, codified at 7 U.S.C. §9, and 

Section 22 of the CEA, as amended, 7 U.S.C. §25, and Regulation 180.1, 17 C.F.R. 

§180.1. 

377. Defendants engaged in a conspiracy to depress prices of the NYMEX 

and ICE May 2020 WTI crude oil futures contracts by selling large volumes of the 

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May 2020 NYMEX WTI crude oil futures contracts and by sending false signals to 

the market, including false price signals resulting from their manipulative and anticompetitive trading that was not reflective of supply and demand. Defendants’ 

cumulative net selling pressure, aggressor sales and later their “ammo” sales sent 

signals to the market of a frenzy of selling. Defendants did not disclose their 

manipulation to the market. 

378. Defendants’ conduct proximately caused injury to Plaintiff and other 

members of the Class who transacted in an artificial and manipulated market at 

artificial and manipulated prices during the Class Period. 

379. Plaintiff and members of the Class are each entitled to damages for 

the violations of the CEA alleged herein. 

AS AND FOR A SIXTH CLAIM 

AGAINST ALL DEFENDANTS 

(Principal-Agent Liability In Violation Of The Commodity Exchange Act 7 

U.S.C. §1 et seq. and Regulation 180.1(a)) 

380. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

381. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants, and John Doe Defendants 1-100 were principals, agents, coventurers and/or guarantors of one another. As agents, co-venturers and/or 

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guarantors of one another, the Defendants engaged in an intentional or reckless use 

of one or more manipulative devices, schemes or artifices to defraud and/or 

engagement in one or more acts, practices, or courses of business, which operated 

or would operate as a fraud or deceit in violation of the CEA as alleged herein on 

behalf of one another and with one another’s knowledge and authorization. 

382. Under Section 2(a)(1)(B) of the CEA, 7 U.S.C. §2(a)(1)(B), 

Defendants are liable for the acts of their agents. 

383. Plaintiff and members of the Class are each entitled to damages for 

the violations of the CEA alleged herein. 

AS AND FOR A SEVENTH CLAIM 

AGAINST ALL DEFENDANTS 

(Aiding and Abetting Liability In Violation Of The Commodity Exchange Act 

7 U.S.C. §1 et seq. and Regulation 180.1(a)) 

384. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

385. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants and John Doe Defendants 1-100 each played their component 

role and each knowingly aided, abetted, counseled, induced, and/or conspired or 

procured the intentional or reckless use of one or more manipulative devices, 

schemes or artifices to defraud and/or engagement in one or more acts, practices, 

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or courses of business, which operated or would operate as a fraud or deceit in 

violation of the CEA as alleged herein. Defendants knew of the manipulative 

devices, schemes or artifices and/or the acts, practices or courses of business that 

operated as a fraud or deceit, intended to help the other Defendants perpetrate such 

manipulative devices, schemes or artifices and/or the acts, practices or courses of 

business that operated as a fraud or deceit and committed one or more acts in 

furtherance of same. 

386. Each of the Vega Trading Defendants utilized or shared trading 

accounts held in the name of Defendant Vega Capital London, Ltd. Defendant 

Spires is the sole director of Defendant Vega Capital. As the sole director of 

Defendant Vega Capital, the entity that held the trading accounts used to make the 

manipulative trades alleged herein, Defendants Spires and Vega Capital knew of 

the manipulative devices, schemes or artifices and/or the acts, practices or courses 

of business that operated as a fraud or deceit, intended to help the other Defendants 

perpetrate same (which generated large profits for the Defendants) and committed 

one or more acts in furtherance of same, including by holding or otherwise 

financing the manipulative positions and/or trades alleged herein. 

387. Each of the Vega Trading Defendant aided and abetted the 

manipulative devices, schemes or artifices and/or the acts, practices or courses of 

business that operated as a fraud or deceit, including by selling large volumes of 

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the May 2020 NYMEX and ICE WTI crude oil futures contracts and by sending 

false signals to the market, including false price signals resulting from their 

manipulative and anti-competitive trading that was not reflective of supply and 

demand. 

388. Under Section 13 of the CEA, 7 U.S.C. §13c(a), Defendants are liable 

for willfully intending to assist the manipulation. 

389. Plaintiff and members of the Class are each entitled to damages for 

the violations of the CEA alleged herein. 

AS AND FOR AN EIGHTH CLAIM 

AGAINST ALL DEFENDANTS 

(Common Law Unjust Enrichment and Restitution/Disgorgement) 

390. Plaintiff incorporates by reference and re-alleges all the allegations in 

this complaint, as though fully set forth herein. 

391. Defendants Vega Capital London, Ltd., Adrian Spires, the Vega 

Trading Defendants and John Doe Defendants 1-100 greatly profited financially 

 from their unlawful acts alleged herein to the 

detriment of Plaintiff and members of the Class. In addition to being unlawful, 

Defendants’ acts were also unfair and inequitable such that permitting Defendants’

retention of their financial benefits resulting from their unlawful and unjust acts 

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alleged herein violates the fundamental principles of justice, equity, and good 

conscience. 

392. Defendants’ unlawful, inequitable and unjust acts alleged herein 

caused Plaintiff and the members of Class to suffer injury, lose money and transact 

at artificial prices. Each Defendant should be required to pay the full amount of its 

own unjust enrichment to Plaintiff and members of the Class. 

393. Plaintiff and members of the Class are entitled to the establishment of 

a constructive trust impressed on the benefits obtained by Defendants from their 

unjust enrichment and inequitable conduct alleged herein. 

PRAYER FOR RELIEF 

 WHEREFORE, Plaintiff prays for relief as follows: 

A. for a declaratory judgment that Defendants combined, conspired and agreed 

to manipulate and fix prices of NYMEX and ICE WTI crude oil futures 

contracts in violation of the Sherman Act, 15 U.S.C. §1 et seq.; 

B. for a declaratory judgment that Defendants intentionally manipulated and 

conspired to manipulate NYMEX and ICE WTI crude oil futures prices, and 

caused such prices to become artificial, in violation of the CEA, 7 U.S.C. §1 

et seq.; 

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C. for a declaratory judgment that Defendants are liable for the acts of their 

agents for their manipulation and conspiracy to manipulate in violation of 

Section 2(a)(1)(B) of the CEA, 7 U.S.C. §2(a)(1)(B); 

D. for a declaratory judgment that Defendants aided and abetted the 

manipulation and conspired to manipulate in violation of Section 13 of the 

CEA, 7 U.S.C. §13c(a); 

E. for a declaratory judgment that Defendants intentionally or recklessly 

employed one or more manipulative devices, schemes or artifices to defraud 

and/or engaged in one or more acts, practices, or courses of business, which 

operated or would operate as a fraud or deceit in violation of section 6(c)(1) 

of the CEA, as amended, codified at 7 U.S.C. §9, and Section 22 of the 

CEA, as amended, 7 U.S.C. §25, and Regulation 180.1, 17 C.F.R. §180.1; 

F. for a declaratory judgment that Defendants are liable for the acts of their 

agents for their intentional or reckless employment of one or more 

manipulative devices, schemes or artifices to defraud and/or engagement in 

one or more acts, practices, or courses of business, which operated or would 

operate as a fraud or deceit in violation of Section 2(a)(1)(B) of the CEA, 7 

U.S.C. §2(a)(1)(B); 

G. for a declaratory judgment that Defendants aided and abetted the intentional 

or reckless employment of one or more manipulative devices, schemes or 

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artifices to defraud and/or engagement in one or more acts, practices, or 

courses of business, which operated or would operate as a fraud or deceit in 

violation of Section 13 of the CEA, 7 U.S.C. §13c(a); 

H. for an order impressing a constructive trust temporarily, preliminarily, 

permanently or otherwise on the full amount of each Defendant’s unjust 

enrichment, including the portions thereof that were obtained at the expense 

of Plaintiff and the Class; 

I. for an order certifying this action as a class action pursuant to Rule 23 of the 

Federal Rules of Civil Procedure, designating Plaintiff as the Class 

representative and his undersigned counsel as Class counsel; 

J. for a judgment awarding Plaintiff and the Class damages against Defendants 

for their violations of the Sherman Act, including treble damages, with 

prejudgment interest at the maximum rate allowable by law; 

K. for a judgment awarding Plaintiff and the Class damages against Defendants 

for each of their violations of the CEA, together with prejudgment interest at 

the maximum rate allowable by law; 

L. for a judgment awarding Plaintiff and the Class damages equal to each 

Defendant’s unjust enrichment, including the portions thereof that were 

obtained at the expense of Plaintiff and the Class; 

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M.for an award to Plaintiff and the Class for their costs of suit, including 

reasonable attorneys’ fees and expert fees and expenses; and 

N. for such other and further relief as the Court may deem just and proper. 

DEMAND FOR JURY TRIAL 

Pursuant to Federal Rule of Procedure 38(b) and otherwise, Plaintiff 

respectfully demands a trial by jury. 

Dated: May 5, 2022 

 Chicago, Illinois 

 Respectfully submitted, 

 /s/ Christopher Lovell 

Christopher Lovell 

 Christopher M. McGrath 

 LOVELL STEWART HALEBIAN 

JACOBSON LLP 

500 Fifth Avenue, Suite 2440 

New York, New York 10110 

Telephone: (212) 608-1900 

Facsimile: (212) 719-4775 

Marvin A. Miller 

Andy Szot 

MILLER LAW LLC 

115 S. LaSalle Street, Suite 2910 

Chicago, Illinois 60603 

Telephone: (312) 332.3400 

Counsel for Plaintiff 

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