1.  Market Volume Increases ......................................................................... 26   2.  Relationship Between Secondary Market Trading and Primary Market  Issuing ....................................................................................................... 28   3.  Regulatory Changes .................................................................................. 29   4.  A Perfect Storm for Collusion .................................................................. 31   5.  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.  61.  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.   62.  Ascertainability. Using, among other things, Defendants’ records, the Class  members are readily ascertainable.   63.  Numerosity.  Due to the nature of the trade and commerce involved, Plaintiff  believes that there are thousands of geographically dispersed Class members, the exact number  and their identities being known to Defendants and their co-conspirators.   64.  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.   66.  Commonality. There are one or more questions of law and/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.   67.  Predominance.  Questions of law and fact common to Class members  predominate over questions affecting only individual Class members.   69.  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.  70.  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   71.  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.   72.  Supranational issuers are institutions whose mandates extend across national  borders and are governed by representatives from a number of countries.  Examples of these  include the World Bank, the African Development Bank, the European Investment Bank  (“EIB”), and the International Finance Corporation (“IFC”).   73.  Sub-sovereign issuers include regional entities that sit at the state or province- level.  Examples include the German states (such as Berlin or Saxony) or Canadian provinces  (Ontario, Alberta, etc.).   74.  Agency bonds that are included in the SSA bond market involve a variety of  quasi-public entities that meet the social or economic public policy mandates.  Examples of these  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  