In re Amaranth Nat. Gas Commodities Litig., No. 12-2075 (2d Cir. 2013)Annotate this Case
Plaintiffs filed suit alleging that Amaranth, a hedge fund, had manipulated the price of natural gas futures in violation of the Commodities Exchange Act (CEA), 7 U.S.C. 1 et seq. Plaintiffs also alleged that J.P. Morgan had aided and abetted Amaranth's manipulation of natural gas futures through J.P. Futures' services as Amaranth's futures commission merchant and clearing broker. On appeal, plaintiffs contend that the district court did not apply the correct standard in evaluating the sufficiency of their amended complaint and likewise failed to recognize the amended complaint's well-pleaded allegations that J.P. Futures aided and abetted Amaranth's manipulation within the meaning of Section 22 of the CEA, 7 U.S.C. 25(a). The court concluded that the district court did not err in concluding that plaintiffs' amended complaint failed to state a claim against J.P. Futures. Because the court concluded that this was so even under the pleading standards that plaintiffs argued should apply, the court did not decide whether the district court's application of a more stringent standard was error.