Chahal v. Credit Suisse Group AG

CourtDistrict Court, S.D. New York
DecidedFebruary 11, 2025
Docket1:18-cv-02268
StatusUnknown

This text of Chahal v. Credit Suisse Group AG (Chahal v. Credit Suisse Group AG) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chahal v. Credit Suisse Group AG, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT D OCUMENT SOUTHERN DISTRICT OF NEW YORK ELECTRONICALLY FILED SET CAPITAL LLC, et al., Individually and on DOC #: ____ ______________ Behalf of All Others Similarly Situated, DATE FILED: _2/11/2025___

Plaintiffs,

-against-

CREDIT SUISSE GROUP AG, CREDIT SUISSE AG, CREDIT SUISSE INTERNATIONAL, 18 Civ. 2268 (AT) TIDJANE THIAM, DAVID R. MATHERS, ORDER Defendants. ANALISA TORRES, District Judge:

Lead Plaintiffs, Set Capital LLC, Stefan Jager, Aleksandr Gamburg, and Apollo Asset Limited,1 bring this class action on behalf of themselves and purchasers, acquirers, sellers, and redeemers of VelocityShares Inverse VIX Short Term Exchange Traded Notes (“XIV Notes” or “notes”) against Defendants, Credit Suisse Group AG, Credit Suisse AG, and Credit Suisse International (together, “Credit Suisse”), Credit Suisse CEO Tidjane Thiam, and CFO David Mathers,2 alleging that Defendants executed a complex fraud to collapse the market for XIV Notes and asserting claims under §§ 9, 10(b), and 20(a) of the Securities Exchange Act of 1934 (the “Exchange Act”), Rule 10b-5 promulgated thereunder, and §§ 11 and 15 of the Securities Act of 1933 (the “Securities Act”). Am. Compl. at 1, ¶¶ 23–24, 26–35, 270–93, 306–23, ECF No. 190. By order dated March 16, 2023 (the “First Order”), the Court granted Lead Plaintiffs’ motion to certify their proposed Securities Act Class but denied certification of their proposed

1 In December 2022, the Court granted Nikolay Drozhzhinov’s request to withdraw as a lead plaintiff. ECF No. 224. 2 In July 2021, Lead Plaintiffs voluntarily dismissed all claims against Janus Henderson Group PLC, Janus Index & Calculation Services LLC, and Janus Distributors LLC without prejudice. ECF No. 160. Misrepresentation Class and Manipulation Class (together, the “Exchange Act Classes”) without prejudice to renewal. See generally First Order, ECF No. 260. Lead Plaintiffs then renewed their motion for certification of the Exchange Act Classes, which the Court again denied without prejudice by order dated March 1, 2024 (the “Second Order”). See generally Second Order, ECF

No. 339. Before the Court is Lead Plaintiffs’ third motion to certify the Exchange Act Classes. Mot., ECF No. 344. For the reasons stated below, the motion is GRANTED in part and DENIED in part. BACKGROUND3 I. Factual Background A. XIV Notes This case arises out of the collapse of XIV Notes, a derivative financial product issued by Credit Suisse that increased in value when market volatility fell and decreased in value when market volatility rose. Am. Compl. ¶¶ 2, 56. XIV Notes were Exchange Traded Notes

(“ETNs”). Id. ¶ 2. In purchasing an ETN, investors pay money to the institution sponsoring the ETN in return for a payment when the note matures, the amount of which is derived from a market index. Id. ¶ 55. In the case of XIV Notes, their value was derived from the S&P 500 VIX Short-Term Futures Index (“VIX Futures Index”), an index that aggregates the value of

3 The Court presumes familiarity with the facts and procedural history of this action, which have been set forth in previous decisions in this case, see, e.g., Set Cap. LLC v. Credit Suisse Grp. AG, 996 F.3d 64, 69–75 (2d Cir. 2021), and restates only key factual and procedural details here. The facts in this section are taken from the amended complaint and are accepted as true for purposes of a motion to certify a class. See Shabazz v. Morgan Funding Corp., 269 F.R.D. 245, 249 (S.D.N.Y. 2010). 2 VIX futures contracts,4 which in turn track expected market volatility. Id. ¶¶ 2, 55–56. This means that when the market expects higher volatility, the VIX Futures Index increases; when the market expects lower volatility, the VIX Futures Index decreases. Id. ¶ 2, 51. To allow investors to profit from low market volatility, the value of XIV Notes was

inverse to the VIX Futures Index. Id. ¶ 2, 56. This inverse relationship between XIV Notes and the VIX Futures Index meant that as market volatility declined and the VIX Futures Index thus decreased, XIV Notes increased in value by an equivalent amount; as market volatility rose and the VIX Futures Index increased, XIV Notes dropped in value by an equivalent amount. Id. Credit Suisse issued XIV Notes on three occasions: in 2010, when it issued 9,018,880 notes; in 2017, when it issued 5,000,000 notes; and on January 29, 2018, when it issued another 16,275,000 notes. Id. ¶¶ 61, 63. The value of XIV Notes increased dramatically over this period. Id. ¶ 62. Because Credit Suisse’s potential liability proportionately increased with the value of XIV Notes, it routinely offset, or “hedged,” its exposure by taking short positions5 on VIX futures contracts. Id. ¶¶ 65–66. This meant that a decrease in the VIX Futures Index would

increase Credit Suisse’s obligation to VIX noteholders but would also allow Credit Suisse to profit from its short positions on VIX futures contracts, offsetting the higher redemption values of XIV Notes. Id. ¶ 66.

4 A futures contract is an agreement to buy or sell a particular commodity or financial instrument on a later date at a predetermined price. Am. Compl. at ii. 5 A short position “is created when a trader sells a security first with the intention of repurchasing it or covering it later at a lower price. A trader may decide to short a security when they believe that the price of that security is likely to decrease in the near future.” James Chen, Short Position: Meaning, Overview, and Example, Investopedia (updated May 29, 2024), https://www.investopedia.com/terms/s/short.asp/. 3 B. Prior Episodes of Market Volatility Although the value of XIV Notes increased on average from 2010 to 2018, three episodes of high market volatility caused the VIX Futures Index to spike and the value of XIV Notes to temporarily drop. Id. ¶ 69. During these episodes of high market volatility, Credit Suisse and

other ETN issuers bought large quantities of VIX futures contracts after market close to continue hedging their positions. Id. ¶¶ 66–69. Each time they did so, there was insufficient liquidity in the VIX futures contracts market; that is, not enough VIX futures contracts to meet the high hedging demand from Credit Suisse and the other ETN issuers. Id. ¶ 69. These post-market-close hedging activities contributed to a liquidity squeeze that made the price of VIX futures contracts soar even higher, which in turn caused the value of XIV Notes to temporarily plummet. Id. ¶¶ 69–74. C. January 2018 XIV Notes As stated above, Credit Suisse issued 16,275,000 XIV Notes on January 29, 2018. Id. ¶ 63. It did so pursuant to a registration statement, prospectus, prospectus supplement, and

pricing supplement (together, the “Offering Documents”), each of which was filed with the Securities and Exchange Commission. Id. ¶¶ 216, 296. The Offering Documents set forth, inter alia, disclosures concerning the risks of investing in the notes and Credit Suisse’s intent to hedge its exposure to the notes. See id. ¶¶ 299–305. For example, the Offering Documents stated that although Credit Suisse had “no reason to believe that [its] hedging activities [would] have a material impact on the level of the [VIX Futures] Index, there [could] be no assurance that the level of the [VIX Futures] Index [would] not be affected.” Id. ¶ 304. The Offering Documents also advised investors of Credit Suisse’s right to accelerate the notes under certain circumstances—that is, to force XIV noteholders to redeem their notes. Id.

4 ¶¶ 73, 137. As relevant here, Credit Suisse could accelerate redemption of the notes if a predefined “acceleration event” occurred, including if the notes’ “intraday indicative value” dropped eighty percent or more from the previous day’s “closing indicative value.”6 Id. ¶ 73.

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