FAQs

A class action is a lawsuit in which one or more people or entities called a “class representative” brings a lawsuit on behalf of itself and other similarly situated persons (i.e., a class) who have similar claims against the defendants. In this case, the class representative is the Oklahoma Firefighters Pension & Retirement System and is called the “representative Plaintiff.” The representative Plaintiff, the court, and counsel appointed to represent the class all have a responsibility to make sure that the interests of all class members are adequately represented.

Importantly, class members are NOT individually responsible for attorneys’ fees or litigation expenses. If the attorneys representing the class get money or benefits for the class in a settlement or judgment, they would ask the court for attorneys’ fees and litigation expenses. If the court approves this request, the fees and expenses would be taken from any money obtained for the class or paid separately by the defendants. If there is no recovery on behalf of the class, the attorneys do not get paid.

When a representative plaintiff enters a settlement with a defendant on behalf of a class, such as this Settlement with Settling Defendants, the court requires that class members are given notice of the settlement and an opportunity to be heard with respect to the settlement. The court then holds a hearing (called a Fairness Hearing) to determine, among other things, if the settlement is fair, reasonable, and adequate.

You received the Notice because you requested it or records show you may be a Settlement Class Member. As a potential Settlement Class Member, you have a right to know about the proposed Settlement with Settling Defendants and your options before the Court decides whether to approve the Settlement.

The Notice explains the Action, the Settlement, your legal rights, what benefits are available, who is eligible for them, and how you can ask for your portion of the benefits if you are eligible. The purpose of the Notice is also to inform you of the Fairness Hearing to be held by the Court to consider the fairness, reasonableness, and adequacy of the Settlement and Plan of Distribution and to consider Plaintiff Counsel’s request for payment of litigation expenses from the Settlement Fund.

Plaintiff alleges that Defendants, a group of banks serving as primary dealers (“Gilt-edged Market Makers” or “GEMMs”) in British pound sterling-denominated UK government bonds (“Gilt Bonds”), as well as their relevant broker-dealer affiliates, entered an unlawful conspiracy to illegally share proprietary and confidential information in real-time through private chatrooms, including details on pricing and other aspects of their trading strategies, to raise, depress, fix, peg, or stabilize the price of Gilt Bonds. Plaintiff alleges this conduct occurred from at least as early as January 1, 2009 through at least December 31, 2013 (the “Class Period”).

Plaintiff alleges that Defendants fixed bid-ask spreads – a bank’s profits on its trading of Gilt Bonds as measured as the difference between the price a bank is willing to purchase (“bid”) or sell (“ask”) the instrument – in the over-the-counter, secondary market through non-public, invitation-only, cross-bank electronic chatrooms, wherein Defendants’ traders discussed proprietary and highly sensitive information on, inter alia, trading strategies, bid and ask prices, and customer order flows. Plaintiff further alleges that it and other Settlement Class Members were injured by these fixed bid-ask spreads each time they transacted in Gilt Bonds directly with a Defendant (or Defendant affiliate). Plaintiff brought a claim under Section 1 of the Sherman Antitrust Act, 15 U.S.C. §1 on behalf of itself and the Settlement Class.

Plaintiff and Plaintiff’s Counsel believe that Settlement Class Members were damaged by Defendants’ conduct. Settling Defendants do not agree with the allegations made by Plaintiff, believe that they have meritorious defenses to Plaintiff’s allegations, and believe that certain of Plaintiff’s claims would have been rejected prior to trial, at trial, or on appeal. The Court has not decided in favor of either Plaintiff or Settling Defendants. Instead, Plaintiff’s Counsel engaged in settlement discussions with Settling Defendants to reach negotiated resolutions of the Action. The Settlement allows both sides to avoid the risks and costs of lengthy litigation and the uncertainty of pre-trial proceedings, a trial, and appeals, and, if approved, they will provide valuable cooperation for Plaintiff to utilize in amending the class’s Complaint. Additionally, the Settlement, if approved, would permit eligible Settlement Class Members who or which submit valid Claims to receive compensation from the Net Settlement Fund, rather than risk ultimately receiving nothing. Plaintiff and Plaintiff’s Counsel believe the Settlement is in the best interest of all Settlement Class Members.

Settling Defendants have agreed to (i) pay $12,000,000 plus Notice and Administration Costs up to $1,000,000 and (ii) provide Plaintiff with Cooperation Materials, including chatroom communications, which Plaintiff can use in its continued prosecution of claims against the non-settling Defendant, Deutsche Bank. In its order dismissing the Complaint, the Court noted the Complaint lacked chatroom communications, which may provide direct or circumstantial evidence of a price-fixing conspiracy. Plaintiff expects to use the Cooperation Materials from Settling Defendants to bolster the allegations against Deutsche Bank in an amended complaint.

If the Settlement is approved, the Settlement Fund, plus interest earned from the date it was established, less any taxes, notice and claims administration costs exceeding $1,000,000 (subject to Court approval), any Court-awarded litigation expenses, and any other costs or fees approved by the Court (the “Net Settlement Fund”) will be divided among all Settlement Class Members who submit valid Claims pursuant to the Plan of Distribution.

Settling Defendants do not think that Plaintiff would have prevailed at trial (had Plaintiff successfully certified a class and survived summary judgment motions), and Settling Defendants believe, as a result, Settlement Class Members would have received nothing.

If the Settlement is approved, Settling Defendants will no longer be defendants in the Action, but the Action will continue against Deutsche Bank. If the Settlement is not approved, Settling Defendants will remain as defendants in the Action, and Plaintiff will continue to pursue its claims against all Defendants.

Plaintiff and Plaintiff’s Counsel believe that Settlement Class Members were damaged by Defendants’ conduct. Settling Defendants do not agree with the allegations made by Plaintiff, believe that they have meritorious defenses to Plaintiff’s allegations, and believe that certain of Plaintiff’s claims would have been rejected prior to trial, at trial, or on appeal. The Court has not decided in favor of either Plaintiff or Settling Defendants. Instead, Plaintiff’s Counsel engaged in settlement discussions with Settling Defendants to reach negotiated resolutions of the Action. The Settlement allows both sides to avoid the risks and costs of lengthy litigation and the uncertainty of pre-trial proceedings, a trial, and appeals, and, if approved, they will provide valuable cooperation for Plaintiff to utilize in amending the class’s Complaint. Additionally, the Settlement, if approved, would permit eligible Settlement Class Members who or which submit valid Claims to receive compensation from the Net Settlement Fund, rather than risk ultimately receiving nothing. Plaintiff and Plaintiff’s Counsel believe the Settlement is in the best interest of all Settlement Class Members.

Settling Defendants have agreed to (i) pay $12,000,000 plus Notice and Administration Costs up to $1,000,000 and (ii) provide Plaintiff with Cooperation Materials, including chatroom communications, which Plaintiff can use in its continued prosecution of claims against the non-settling Defendant, Deutsche Bank. In its order dismissing the Complaint, the Court noted the Complaint lacked chatroom communications, which may provide direct or circumstantial evidence of a price-fixing conspiracy. Plaintiff expects to use the Cooperation Materials from Settling Defendants to bolster the allegations against Deutsche Bank in an amended complaint.

If the Settlement is approved, the Settlement Fund, plus interest earned from the date it was established, less any taxes, notice and claims administration costs exceeding $1,000,000 (subject to Court approval), any Court-awarded litigation expenses, and any other costs or fees approved by the Court (the “Net Settlement Fund”) will be divided among all Settlement Class Members who submit valid Claims pursuant to the Plan of Distribution.

Settling Defendants do not think that Plaintiff would have prevailed at trial (had Plaintiff successfully certified a class and survived summary judgment motions), and Settling Defendants believe, as a result, Settlement Class Members would have received nothing.

If the Settlement is approved, Settling Defendants will no longer be defendants in the Action, but the Action will continue against Deutsche Bank. If the Settlement is not approved, Settling Defendants will remain as defendants in the Action, and Plaintiff will continue to pursue its claims against all Defendants.

In the order preliminarily approving the Settlement, the Court preliminarily certified the following Settlement Class:

All persons or entities who entered into Gilt Bond Transactions in the United States directly with Defendants from January 1, 2009 to December 31, 2013.

Excluded from the Class are Defendants and past and present direct or indirect parent (including holding companies), subsidiary, affiliate, associate, or divisions of a Defendant; provided, however, that Investment Vehicles shall not be excluded from the definition of “Settlement Class” or “Class.” In addition, the U.S. Government and any judicial officer presiding over this Action and the members of his or her immediate family and judicial staff and any juror assigned to this Action are excluded from the Settlement Class.

Settling Defendants have agreed to (i) pay $12,000,000 plus notice and administration costs up to $1,000,000 and (ii) provide Plaintiff with Cooperation Materials, including but not limited to, documents and data, depositions, and/or declarations to establish authenticity and admissibility of documents produced by Settling Defendants, and additional documents or data which Plaintiff may reasonably request. Plaintiff’s Counsel believe the Cooperation Materials will aid the continued prosecution of the Action against the non-settling Defendant, Deutsche Bank.

 If you are a Settlement Class Member and do not opt out, you will be eligible to file a Proof of Claim and Release Form. The amount of your payment will be determined by a Plan of Allocation. Details about the Plan of Allocation are available at www.GiltBondSettlement.com or by calling toll-free 1-877-354-3915 (if calling from outside the United States or Canada, call 1-414-961-6555). A date for distribution of the Settlement Fund has not been set.

Proof of Claim and Release Forms must be submitted by December 23, 2025.

The Court will hold the Settlement Hearing on January 22, 2026, at 2:30 p.m. EST to decide whether to approve the Settlement, Plan of Distribution, and request for litigation expenses. If the Court approves the Settlement and Plan of Distribution, there may be appeals after that. It can sometimes take a year or more for the appellate process to conclude.

Please be patient and continue to check status updates at www.GiltBondSettlement.com.

After you submit your Claim, the Claims Administrator will evaluate it to determine if you have provided sufficient information to show you are a Settlement Class Member and calculate your payment. If the Claims Administrator determines that your Claim is deficient or defective, it will contact you. If you subsequently provide information that satisfies the Claims Administrator about the validity of your Claim, you will not have to do anything else. If any disputes cannot be resolved, Plaintiff’s Counsel will submit them to the Court, and the Court will make a final determination about the validity of your Claim. The Court’s decisions about any objections to the Claims Administrator’s claim determinations will be final and binding, and there is no right to appeal the Court’s determination.

Unless you exclude yourself, you remain a Settlement Class Member. That means you can’t sue, continue to sue, or be part of any other lawsuit about the Released Claims in this Action against Settling Defendants. It also means that all of the Court’s orders related to this Settlement will apply to you and legally bind you.

Upon the Effective Date of the Settlement, Plaintiff and all Settlement Class Members shall be deemed to have, and by operation of the Judgments shall have, fully, finally, and forever waived, released, relinquished, and discharged all Released Claims against the Settling Defendants. The capitalized terms used in this paragraph are defined in the Stipulation, order preliminarily approving the Settlement, or this Notice. For easy reference, certain of these terms are copied below:

• “Released Claims” means any and all claims, counterclaims, demands, actions, potential actions, suits, and causes of action, losses, obligations, damages, matters and issues of any kind or nature whatsoever, and liabilities of any nature, whether foreign or domestic, including without limitation claims for costs, expenses, penalties, and attorneys’ fees, whether class, individual, or otherwise, that the Plaintiff and Settlement Class, or any of them, ever had or now have directly, representatively, derivatively or in any other capacity against any of the Released Defendant Persons, whether known claims or Unknown Claims, suspected or unsuspected, asserted or unasserted, foreseen or unforeseen, actual or contingent, accrued or unaccrued, matured or unmatured, disclosed or undisclosed, apparent or unapparent, liquidated or unliquidated, or claims that have been, could have been, or in the future might be asserted in law or equity, on account of or arising out of or resulting from or in any way related to any conduct that was alleged or could have been alleged in the Action based on any or all of the same factual predicate of the Action, including but not limited to any claims arising from or related to any purported conspiracy, collusion, manipulation, improper sharing of information, or any other improper conduct relating to a Gilt Bond Transaction. Released Claims shall not include: (i) any claims relating to the enforcement of the Settlement; (ii) claims related to the enforcement of the underlying terms of an existing Gilt Bond Transaction; or (iii) any claims of any person or entity that submits a request for exclusion and whose request is accepted by the Court.
• “Released Plaintiff Persons” means (a) Plaintiff and all Settlement Class Members; and (b) each of their Related Persons.
• “Released Defendant Persons” means (a) each Settling Defendant, and (b) each Settling Defendant’s Related Persons.
• “Related Persons,” when used in reference to a Person, means (a) the Person; (b) for natural persons, each of that Person’s respective immediate family members and any trust which that Person is the settlor of or which is for the benefit of any such Person and/or the members of his or her family, and, (c) for non-natural persons, each of past, present, and future, direct and indirect corporate parents (including holding companies), subsidiaries, related entities and affiliates, associates, predecessors, and successors; and (d), for any of the entities or Persons listed at (a), (b), or (c) above, their respective past, present, or future parents, subsidiaries and affiliates, and their respective directors, officers, managers, managing directors, partners, members, principals, employees, auditors, accountants, representatives, insurers, trustees, trustors, agents, attorneys, professionals, predecessors, successors, assigns, heirs, executors, and administrators, in their capacities as such, and any entity in which the Person has a controlling interest.

By remaining a Settlement Class Member, you do not give up any of your claims against the non-settling Defendant, Deutsche Bank.

You are automatically a Settlement Class Member if you fit the Settlement Class description. You will be bound by past and any future Court rulings, including rulings on the Settlement and Releases. Unless you exclude yourself, you will not be able to start a lawsuit, continue with a lawsuit, or be a part of any other lawsuit against Settling Defendants or any of the other Released Defendant Persons based on the Released Claims. Please see question 16 for a description of the Released Claims.

You can exclude yourself by sending a written “Request for Exclusion.” You cannot exclude yourself by telephone or email. You must mail your written Request for Exclusion, so it is received by December 23, 2025 to Gilt Bond Antitrust Settlement Exclusions c/o A.B. Data, Ltd., P.O. Box 173001, Milwaukee, WI 53217. Requests for Exclusion must contain:

(i)         Your name, address, telephone number, and any e-mail contact information of the person seeking exclusion.

(ii)         A list of all trade names or business names that you request to be excluded (if applicable);

(iii)        A statement that the person “requests to be excluded from the Settlement Class in Oklahoma Firefighters Pension & Retirement System v. Deutsche Bank AG, et al, Case No. 1:23-cv-05095 (S.D.N.Y.)”.

(iv)        Proof of membership in the Settlement Class

(v)        The signature and date of signature of the person seeking exclusion from the Settlement Class.

A Request for Exclusion that does not include all the required information, does not contain the proper signature, is sent to an address other than the one designated above, or is not received by December 23, 2025, will be considered invalid and the person(s) filing such an invalid request shall be a Settlement Class Member and shall be bound by the Settlement, if approved.

 

Settlement Class Members are not allowed to exclude other Settlement Class Members. Moreover, group or class-wide exclusions are not permitted. A Request for Exclusion must be submitted by each Settlement Class Member on an individual basis, and any Request for Exclusion by a purported authorized agent or representative of a Class Member must include proof of the representative’s legal authority and authorization to act and request exclusion on behalf of each Settlement Class Member they seek to opt out.

All persons who submit valid and timely Requests for Exclusion in the manner set forth above shall have no rights under the Settlement and will not be bound by the Settlement. Such persons will not be precluded from participating in a future settlement, if any, or participating in any certified litigation classes in the Action in the future.

Requests for Exclusion must be sent by U.S. first class mail (preferably certified mail) (or, if sent from outside the U.S., by a service that provides for guaranteed delivery within five (5) or fewer calendar days of mailing) to the Claims Administrator at:

Gilt Bond Antitrust Settlement Exclusions

c/o A.B. Data, Ltd.

P.O. Box 173001

Milwaukee, WI 53217

Requests for exclusion must be received no later than December 23, 2025.

If you are a Settlement Class Member and you do not exclude yourself, you can tell the Court what you think about the Settlement, the Plan of Distribution, and/or Plaintiff Counsel’s request for payment of litigation expenses from the Settlement Fund. The Court will consider your views.

You can also ask to appear and speak at the Fairness Hearing in this Action, at your own expense, individually or through counsel of your own choice.

If you want to make an objection and/or you want to ask to appear at the Fairness Hearing, you must file your objection and/or notice of appearance with the Clerk of Court by December 23, 2025, and serve copies of your objection and/or notice of appearance on Plaintiff’s Counsel and Settling Defendants’ Counsel at the following physical addresses:

Scott+Scott Attorneys at Law LLP Attn: Patrick J. Coughlin 600 W. Broadway, Suite 3300 San Diego, CA 92101
Plaintiff’s Counsel
Skadden, Arps, Slate, Meagher & Flom LLP Attn: Boris Bershteyn One Manhattan West New York, NY 10001	Willkie Farr & Gallagher LLP Attn: Katrina M. Robson 1875 K Street, N.W. Washington, D.C. 20006
Counsel for Citigroup	Counsel for HSBC
Sullivan & Cromwell LLP Attn: Alexander J. Willscher 125 Broad Street New York, NY 10004	Cravath, Swaine, & Moore LLP Attn: Michael A. Paskin 375 Ninth Ave. New York, NY 10001
Counsel for RBC	Counsel for Morgan Stanley

Any Settlement Class Member who does not enter an appearance will be represented by Plaintiff’s Counsel.

If you choose to object, you must file a written objection. You cannot make an objection by telephone or email. Your written objection must substantially comply with the following requirements. It must set forth the Settlement Class Member’s:

(a) name, address, and telephone number,

(b) proof of membership in the Settlement Class,

(c) grounds for the objection, and

(d) the name, address, and telephone number of the Settlement Class Member’s counsel, if any. In addition, the objection must also

(e) state whether it applies only to the objector, to a specific subset of the class, or to the entire class, and state with specificity the grounds for the objection and

(f) include a list of all class action settlements to which you and/or your counsel have previously objected. The objection must also

(g) be signed by the objector, even if the objection is filed by counsel for the objector.

If you do not timely and validly submit your objection, your views may not be considered by the Court or any court on appeal.

Objecting is telling the Court that you do not like something about the Settlement. You can object to the Settlement only if you remain a Settlement Class Member and do not exclude yourself from the Settlement. Excluding yourself from the Settlement is telling the Court that you do not want to be a part of the Settlement Class. If you exclude yourself, you have no right to object to the Settlement because it no longer affects you.