Second Circuit Affirms Win for Citigroup in SSA Bond Antitrust Litigation

On July 19, on behalf of Citigroup Inc. and three of its affiliates, Skadden obtained an affirmance by the U.S. Court of Appeals for the Second Circuit of the dismissal of federal antitrust claims alleging a price-fixing conspiracy in the U.S. market for supranational, sub-sovereign and agency bonds. The Second Circuit affirmed the district court’s dismissal of the plaintiffs’ claims against all defendants on the grounds that the conspiracy alleged is implausible. Specifically, the court concluded that the plaintiffs failed to provide sufficient factual detail to support the broad conspiracy alleged involving all defendants and affecting every single trade with the defendants over seven years.