In re Foreign Exchange Benchmark Rates Antitrust Litigation

District Court, S.D. New York·Decided October 11, 2022·No. 1:13-cv-07789·Unknown

Opinion

Credit Suisse's application is DENIED. Testimony on the topic at issue is fairly within the scope of Mr. Robin’ previously disclosed opinions for substantially the reasons stated below by Plaintiffs. Dated: October 10, 2022 New York, New York |

LORNA G. SCHOFIEL UNITED STATES DISTRICT JUDGE Re: Inre Foreign Exchange Benchmark Rates Antitrust Litigation Case No. 1:13-cv-07789-LGS Dear Judge Schofield: The parties have a dispute regarding the scope of the testimony of Plaintiffs’ foreign exchange industry expert, Eric Robin, who Plaintiffs have indicated they intend to call on October 11 or October 12. Credit Suisse’s Position: This Court ruled on September 6, 2022 that “all experts’ testimony at trial will be limited to opinions that were timely disclosed in their expert reports.” See Order on Plaintiffs’ Motion to Strike (ECF No. 1882). On October 7, 2022, Plaintiffs served their updated witness list, adding for the first time the following topic of anticipated testimony for Mr. Robin: “spread[s] shown to customers are confidential bank information.” Mr. Robin did not disclose any opinion on this topic in either of the two expert reports he submitted during expert discovery (on January 23, 2020 and August 13, 2020, respectively), and this topic was not listed for Mr. Robin in Plaintiffs’ witness list filed as part of the Parties’ Joint Pre-Trial Order (ECF No. 1853) (Aug. 26, 2022).' Indeed, neither of Mr. Robin’s reports even use the phrase “confidential bank information,” let alone contains an opinion that “spreads shown to customers” constitute confidential bank information. Furthermore, neither report provides any basis or reasons to support an expert opinion by Mr. Robin—a former FX salesperson—that spreads (whether “shown to customers” or otherwise) are confidential bank information. See Fed. R. Civ. Pro. 26(a)(2)(B) (an expert report must contain “a complete statement of all opinions the witness will express and the basis and reasons for them’) (emphasis added). Because Mr. Robin did not properly disclose this opinion in his expert reports, he also cites no basis in any regulation, or bank policy, or any other authority to support any expert opinion on this topic.

' While, of course, it is an expert’s report that controls on the issue of whether an opinion has been properly disclosed, Plaintiffs originally listed only three topics for Mr. Robin in the Parties’ Joint Pre-Trial Order (ECF No. 1853) (Aug. 26, 2022): “Eric Robin is an expert on the FX industry. Mr. Robin will testify about (1) the basics of the FX market and FX trading, with primary emphasis on FX spot transactions; and (2) what a ‘spread’ is in FX trading and how spreads constitute market makers’ source of profit and customers’ cost of trading; (3) the durability of and correlations across spreads.”

When Credit Suisse promptly raised this issue with Plaintiffs’ Counsel on October 8, 2022, Plaintiffs pointed to four paragraphs (¶¶ 7-10) in Mr. Robin’s reply expert report that they claim disclose Mr. Robin’s opinion on this topic. An excerpt from Mr. Robin’s report, with the full text of these paragraphs, is attached as Exhibit A. None of these paragraphs come close to disclosing an opinion that spreads are “confidential bank information,” or to defining what “confidential bank information” means in this context, or to explaining what qualifies Mr. Robin to offer expert opinions on this subject. Neither Mr. Robin’s reference to “market color,” nor his criticisms of Dr. Melvin’s opinions as to the benefits of sharing market color, discloses an opinion by Mr. Robin that spreads are “confidential” or the basis for any such opinion. That Plaintiffs believed it was necessary to add this separate topic to their updated witness list only further belies any argument that this topic already fell within Mr. Robin’s prior disclosed opinions, or that it can be simply swept into Plaintiffs’ general disclosure that Mr. Robin was to opine on “what a ‘spread’ is in FX trading and how spreads constitute market makers source of profit and customers’ cost of trading.”2 Plaintiffs have further argued that it has long been a contention of Plaintiffs that spreads are confidential “Competitively Sensitive Information” (“CSI”)—a term used and defined by Plaintiffs’ former—now withdrawn—expert, Robin Poynder.3 Plaintiffs’ argument only highlights their long-held position that the classification of certain information as “confidential” or “CSI” is a matter for expert opinion and thus, that such expert opinions must be disclosed under Rule 26. Moreover, Plaintiffs’ argument misses the point. Plaintiffs cannot simply transfer the disclosed opinions of their abandoned expert to another testifying expert where they have not satisfied the expert disclosure requirements. Even if such tactics were permitted under the Federal Rules (and they are not), Plaintiffs have never disclosed Mr. Robin’s purported basis for adopting any such opinion of Mr. Poynder’s. And the Federal Rules require the disclosure of both “a complete statement of all opinions the witness will express” and “the basis and reasons for them.” Finally, Plaintiffs’ tactical decision months ago to drop their former expert on this subject, Mr. Poynder, prevented Credit Suisse from challenging whether any opinion on this topic is even a proper subject of expert testimony or whether Mr. Robin (or Mr. Poynder) is qualified to give it. Plaintiffs should not be permitted to reinsert this topic on the eve of trial. Mr. Robin has never disclosed an opinion on the issue of whether spreads constitute confidential bank information. He should be prohibited from opining on the topic in accordance with Rule 26(a)(2) and this Court’s September 6, 2022 Order. 2 Parties’ Joint Pre-Trial Order (ECF No. 1853) (Aug. 26, 2022). 3 See, e.g., Jan. 23, 2020 Expert Report of Robin Poynder ¶ 2 (“I was asked to focus on pricing, order, or customer information that FX traders at other banks could exploit to their advantage, to their customers’ disadvantage, or both—as distinguished from generalised commentary or ‘market colour’. I refer to this type of information throughout my report as ‘Competitively Sensitive Information’ (‘CSI’)...”). Plaintiffs’ Position Credit Suisse is manufacturing a dispute, objecting to Plaintiffs providing more granular information regarding the proposed testimony of Plaintiffs’ FX industry expert, Eric Robin, in their October 7, 2022, witness list. Contrary to Credit Suisse’s feigned surprise, this additional explanation is not a new subject, but was properly included in both the long-disclosed general topics and covered in Mr. Robin’s August 13, 2020 Rebuttal Report. The Court should deny Credit Suisse’s request. The Joint Pre-Trial Order which detailed the subject of testimony for Mr. Robin provides: “Eric Robin is an expert on the FX industry. Mr. Robin will testify about (1) the basics of the FX market and FX trading, with primary emphasis on FX spot transactions; and (2) what a ‘spread’ is in FX trading and how spreads constitute market makers’ source of profit and customers’ cost of trading; (3) the durability of and correlations across spreads.” August 26, 2022 ECF 1853 at 6. The additional detail Plaintiffs provided is plainly encompassed by Topics 1 and 2. Explanation of the market and what a spread is in FX trading necessarily include information regarding how that information is kept, used, and understood in the market. Credit Suisse’s complaint that adding “spreads shown to customers are confidential bank information” and is “outside of Robin’s disclosed opinions” is nonsense. Mr. Robin’s Rebuttal Report contains a section entitled: “FX Traders Do Not Need to Exchange CSI [Competitively Sensitive Information].” Rebuttal Report, ¶¶7-10. Responding to Credit Suisse’s expert, Mr. Robin opined: “Based on my experience in the industry and the record evidence, the types of information exchanged between FX traders durin

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In re Foreign Exchange Benchmark Rates Antitrust Litigation, (S.D.N.Y. 2022).

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