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On March 17, 2021, the United States Court of Appeals for the
Second Circuit ("Second Circuit") overturned the decision of the United States
District Court for the Southern District of New York
("District Court") dismissing
Fund Liquidation
Holdings, LLC v. Bank of America Corporation, et al. In so
doing, the Second Circuit revived antitrust class action claims
against a number of banks, which alleged that the banks manipulated
the Singapore Interbank Offer Rate ("SIBOR") and the
Singapore Swap Offer Rate (SOR) between 2007 and 2011. Two Cayman
Island investment funds-FrontPoint Asian Driven Fund, L.P., and