 Market Volume Increases ......................................................................... 26    Relationship Between Secondary Market Trading and Primary Market  Issuing ....................................................................................................... 29    Regulatory Changes .................................................................................. 29    A Perfect Storm for Collusion .................................................................. 31    Dealers Collude to Increase Spreads ......................................................... 35  C.  News Reports of Regulatory Investigations into the SSA Market ....................... 36  D.  Defendants Terminate or Suspend SSA Traders as the Government Investigations  Are Revealed ......................................................................................................... 38  VI.   Class Definition.  Pursuant to Rules 23(a) and (b)(3) of the Federal Rules of Civil  Procedure, Plaintiff brings this action on behalf of itself and on behalf of the following “Class”:  All persons who, between January 1, 2010 and April 27, 2014  (inclusive) purchased or sold a U.S. dollar-denominated SSA bond  in the secondary SSA bond market directly to or from a Defendant,  where such persons were either domiciled in the United States or  its territories or, if domiciled outside the United States or its  territories, purchased or sold (as set forth above) one or more  USD-denominated SSA bond in the United States or its territories.    Exclusions from the Class.  Excluded from the Class are Defendants and their co- conspirators.  For the Bank Defendants and their co-conspirators, this includes their subsidiaries  and affiliates, as well as the directors, members, partners, managers, officers, employees, and  agents of both the Bank Defendants and their subsidiaries and affiliates.  For the Trader  Defendants, this includes any entity in which they have a controlling interest, their legal  representatives, heirs, assigns or any other person acting on their behalf.  Also excluded from the  Class are any judicial officer presiding over this action and the members of his/her immediate  family and judicial staff, and any juror assigned to this action.    Ascertainability. Using, among other things, Defendants’ records, the Class  members are readily ascertainable.    Typicality.  Plaintiff’s claims are typical of the claims of Class members.   Defendants’ wrongful common course of conduct in violation of the law directly and  proximately caused the damages and injuries of Plaintiff and each member of the Class. There  are no defenses that are unique to Plaintiff.    Adequacy.  Plaintiff will protect the interests of the Class. Plaintiff’s interests are  aligned with, and not antagonistic to, the Class members.  Plaintiff has retained counsel  competent and experienced in the prosecution of class actions and antitrust litigation to represent  itself and the other Class members.    Commonality. There are one or more questions of law or fact common to the  Class, including, but not limited to:  a.  whether Defendants and their co-conspirators engaged in an agreement,  combination, or conspiracy to fix, raise, elevate, maintain, or stabilize  USD-denominated SSA bond bid/ask spreads in interstate commerce in  the United States;  b.  the identity of the participants of the conspiracy or manipulative scheme;  c.  the duration of the conspiracy scheme alleged herein and the acts  performed by Defendants and their co-conspirators in furtherance thereof;  d.  whether the alleged conspiracy violated Sections 1 and 3 of the Sherman  Act, 15 U.S.C. §§1 and 3;  e.  whether the conduct of Defendants and their co-conspirators, as alleged in  this Complaint, caused injury to Plaintiff and Class members; and  f.  the appropriate measures of damages for the Class.    Predominance.  Questions of law or fact common to Class members predominate  over questions affecting only individual Class members.    The Class is defined herein based on currently available information and Plaintiff  hereby reserves the right to amend the definition of members of the Class, including, without  limitation, the Class Period.  V.   The SSA bond market is a large global market.  According to Bloomberg  estimates, the SSA bond market is valued from $9 trillion to $15 trillion.  The SSA bond market  experienced significant growth in the past decade, having tripled from 2005 to 2012.  In 2015,  new issues in SSA bonds reached $843.35 billion.8    Governmental or quasi-governmental, supranationals, sub-sovereigns, and  agencies issue SSA bonds to raise capital for a variety of public (i.e., social, infrastructure,  policy, economic development) purposes worldwide.  8   See Abhinav Ramnarayan and Helene Durand., DoJ investigates bond traders over  market-rigging,  A.  The SSA Bond Market   V.  SUBSTANTIVE FACT ALLEGATIONS ....................................................................... 22  A.  The SSA Bond Market .......................................................................................... 22  B.  Changes Affecting the SSA Bond Market ............................................................ 26  