2nd Circuit Vacates Dismissal Of LIBOR Suit

(May 24, 2016, 1:32 PM EDT) -- NEW YORK — A Second Circuit U.S. Court of Appeals panel on May 23 vacated an order dismissing a case alleging manipulation of the U.S. Dollar London Interbank Offered Rate (LIBOR) that had been consolidated with others in a multidistrict litigation, finding that horizontal price-fixing constitutes a per se antitrust violation, a plaintiff alleging such a violation does not need to separately plead harm to competition and a consumer who pays a higher price on account of horizontal price-fixing suffers antitrust injury (Ellen Gelboim, et al. v. Bank of America Corporation, et al., Nos. 13-3565, 13-3636, 15-432, 15-441, 15-454, 15-477, 15-494, 15-498, 15-524, 15-537, 15-547, 15-551, 15-611, 15-620, 15-627, 15-733, 15-744, 15-778, 15-825 and 15-830, 2nd Cir.; 2016 U.S. App. LEXIS 9366)....

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