Adm aot memo in opposition

UNITED STATES DISTRICT COURT
CENTRAL DISTRICT OF ILLINOIS
URBANA DIVISION
AOT HOLDING AG, individually and on
behalf of all others similarly situated,
Plaintiff,
v.
ARCHER DANIELS MIDLAND
COMPANY,
Defendant.
Case No. 19-CV-2240-CSB-EIL
Hon. Colin S. Bruce
AOT’s MEMORANDUM IN OPPOSITION
TO ADM’s MOTION TO DISMISS
E-FILED
Monday, 18 November, 2019 05:20:17 PM
Clerk, U.S. District Court, ILCD
2:19-cv-02240-CSB-EIL # 20 Page 1 of 29

i
TABLE OF CONTENTS
INTRODUCTION AND FACTUAL SUMMARY...................................................................................1
LEGAL STANDARD......................................................................................................................................4
ARGUMENT ....................................................................................................................................................4
1. AOT’s complaint easily satisfies Twombly’s “plausibility” standard...........................................4
1.1 ADM advocates for a “probability” pleading standard rejected by Twombly and
subsequent decisions.........................................................................................................5
1.2 AOT’s allegations are far stronger than the allegations in Twombly............................6
2. AOT has plausibly alleged a manipulation claim under the CEA......................................10
3. AOT has plausibly alleged that it was injured as a result of ADM’s manipulation..........14
4. The Court should reject ADM’s unsupported attempt to chisel away at AOT’s class
allegations at the motion-to-dismiss stage..............................................................................17
5. The CEA permits punitive damages.......................................................................................19
6. AOT can pursue all legal theories under the CEA that are consistent with its alleged
facts..............................................................................................................................................20
CONCLUSION...............................................................................................................................................21
2:19-cv-02240-CSB-EIL # 20 Page 2 of 29

ii
TABLE OF AUTHORITIES
Page(s)
Cases
Abbott v. Lockheed Martin Corp.,
725 F.3d 803 (7th Cir. 2013)....................................................................................................................17
Alden Mgmt. Servs., Inc. v. Chao,
532 F.3d 578 (7th Cir. 2008)....................................................................................................................20
In re Amaranth Nat. Gas Commodities Litig.,
269 F.R.D. 366 (S.D.N.Y. 2010)...................................................................................................... 14, 15
Ashcroft v. Iqbal,
556 U.S. 662 (2009).................................................................................................................................4, 5
Bartholet v. Reishauer A.G. (Zürich),
953 F.2d 1073 (7th Cir. 1992)..................................................................................................................20
Bell Atlantic v. Twombly,
550 U.S. 544 (2007).............................................................................................................................passim
Butler v. Sears, Roebuck & Co.,
727 F.3d 796 (7th Cir. 2013)....................................................................................................................17
In re Dairy Farmers of America, Inc. Cheese Antitrust Litig.,
801 F.3d 758 (7th Cir. 2015).......................................................................................................10, 11, 12
Dennis v. JPMorgan Chase & Co.,
343 F. Supp. 3d 122 (S.D.N.Y. 2018).............................................................................................. 18, 19
Erickson v. Pardus,
551 U.S. 89 (2007).......................................................................................................................................5
Forseth v. Vill. of Sussex,
199 F.3d 363 (7th Cir. 2000)....................................................................................................................20
Hall v. Nalco Co.,
534 F.3d 644 (7th Cir. 2008)....................................................................................................................20
Khalid Bin Talal v. E.F. Hutton,
720 F. Supp. 671 (N.D. Ill. 1989) ...........................................................................................................19
Kohen v. Pacific Investment Management Co. LLC,
244 F.R.D. 469 (N.D. Ill. 2007), aff’d 571 F.3d 672 (7th Cir. 2009)...................................................15
2:19-cv-02240-CSB-EIL # 20 Page 3 of 29

iii
In re LIBOR-Based Fin. Instruments Antitrust Litig.,
962 F. Supp. 2d 606 (S.D.N.Y. 2013).....................................................................................................16
O’Grady v. Vill. of Libertyville,
304 F.3d 719 (7th Cir. 2002)....................................................................................................................20
Payton v. County of Kane,
308 F.3d 673 (7th Cir. 2002)....................................................................................................................18
Ploss v. Kraft Foods Group, Inc.,
197 F. Supp. 3d 1037 (N.D. Ill. 2016)....................................................................................................13
Swanson v. Citibank, N.A.,
614 F.3d 400 (7th Cir. 2010).......................................................................................................4, 5, 6, 10
Wilson v. Ryker,
451 F. App’x 588 (7th Cir. 2011)............................................................................................................20
Statutes
7 U.S.C. § 6b(a).................................................................................................................................................20
7 U.S.C. § 6c(a).................................................................................................................................................20
7 U.S.C. § 13(a)(2)............................................................................................................................................10
7 U.S.C. § 25(a).......................................................................................................................................... 10, 20
7 U.S.C. § 25(a)(3)............................................................................................................................................19
Futures Trading Practices Act of 1992, Pub. L. No. 102-546, § 222, 106 Stat 3590,
3617.............................................................................................................................................................19
Other Authorities
17 C.F.R. § 180.2..............................................................................................................................................10
Federal Rule of Civil Procedure 8(a)(2)..........................................................................................................4
Federal Rule of Civil Procedure 23 ...............................................................................................................18
Federal Rule of Civil Procedure 23(c)(4)............................................................................................... 17, 18
2:19-cv-02240-CSB-EIL # 20 Page 4 of 29

iv
GLOSSARY OF TERMS
ADM
Defendant Archer Daniels Midland Company.
AOT
Plaintiff AOT Holding AG.
Argo
A fuel terminal located in Argo, Illinois. Trading at the Argo terminal during the half-hour MOC
window determines the Chicago Benchmark Price that sets the value of Chicago Ethanol
Derivatives.
CEA
The Commodities Exchange Act, 7 U.S.C. § 1 et seq.
Chicago Benchmark Price
The daily price of ethanol traded at Argo terminal. It is determined by Platts based on ethanol
trading during the MOC window. This price serves as the basis for the value of the Chicago Ethanol
Derivatives.
Chicago Ethanol Derivatives
Ethanol futures contracts and options contracts traded on the Chicago Mercantile Exchange. The
value of these instruments is determined wholly or in part by the Chicago Benchmark Price. The
most important derivatives are (1) the Chicago Ethanol (Platts) Futures contract (CME symbol: CU)
traded on NYMEX; (2) the Chicago Ethanol (Platts) Average Price Option (CME symbol: CVR)
traded on NYMEX; and (3) the CME’s Ethanol Futures Contract (CME symbol: EH) traded on
CBOT.
Decay
The phenomenon that occurs where a fixed percentage of the open position in a diminishing
balance contract held by an investor is “locked in” based on each day’s trading price. The amount of
decay can be determined by the number of open positions held by an investor divided by the
number of trading days in the particular month. This decay occurs because each trading day’s
settlement price has a proportional impact on the final settlement value of the contract at the end of
the month.
Diminishing Balance Contract
Specific futures contracts whose front month position in any given contract month diminishes as the
contract month progresses toward expiration at the end of the month for purposes of position
limits. Diminishing balance contracts typically have a final settlement value equal to the average of
2:19-cv-02240-CSB-EIL # 20 Page 5 of 29

v
the benchmark price for all trading days in the contract month. Chicago Ethanol (Platts) Futures are
diminishing balance contracts.
Hitting the Bid
A phrase that describes a consummated trade where a seller agrees to match a buyer’s posted bid
quotation price. “Hitting the bid” is the opposite of “lifting the offer,” where a buyer agrees to
match a seller’s offer quotation for the product.
Long
A trading position where a derivative investment earns money for a trader if the price of the
underlying commodity increases.
MOC
The Market-on-Close (“MOC”) window is a 30-minute trading period for ethanol transactions
between 1:00 p.m. and 1:30 p.m. C.T. every trading day at Argo terminal. Platts uses trading activity
during the MOC to determine the daily Chicago Benchmark Price for ethanol.
Platts
S&P Global Platts (“Platts”) is a provider of trading information in the ethanol market and other
markets. Platts creates the daily Chicago Benchmark Price that determines the value of Chicago
Ethanol Derivatives.
Short
A trading position where a derivative investment earns money for a trader if the price of the
underlying commodity decreases.
2:19-cv-02240-CSB-EIL # 20 Page 6 of 29

1
INTRODUCTION AND FACTUAL SUMMARY
AOT’s complaint lays out a detailed and compelling account of how, starting in November
2017 and continuing through the filing of this lawsuit, ADM has flooded Argo with ethanol that it
intentionally sold at artificially low prices in order to juice the profits on its outsized short positions
in related ethanol derivatives. The complaint details how ADM dramatically shifted from buying to
selling ethanol at Argo at the start and for the duration of the alleged manipulation period;
continued to produce and sell at Argo even as prices fell and profits evaporated; sold at Argo for less
than it could have received elsewhere; sold at prices below its variable cost of production; and priced
ethanol so aggressively during the MOC window that it captured 90% of all sales influencing the
Chicago Benchmark Price, despite having only a 10% share of the U.S. ethanol market.
ADM does not squarely address these critical facts and instead spins a few isolated
allegations into an alternative story of ADM simply acting in accordance with its rational business
interests as an ethanol producer. For example, ADM suggests that, in light of the ethanol supply glut
during the alleged manipulation period, it is equally likely that its aggressive selling at Argo was
motivated by an economically rational desire to liquidate existing ethanol stock before prices
dropped further. (Mem. at 1, 2.) ADM also suggests that its production capacity and proximity to
Argo allowed it to undercut the prices of other ethanol producers, which implies “nothing other
than ordinary competition.” Id. But ADM’s alternative story quickly falls apart when confronted
with the totality of AOT’s allegations.
First, the ethanol supply glut did not trigger ADM’s overnight transition into a pure seller
during Argo’s benchmark-setting MOC window. That glut began well before November 2017, and
during that time ADM was the predominant buyer of ethanol at Argo, including during the MOC
window. (¶¶ 5, 71.) Yet starting that month and continuing through the filing of this case, ADM
transformed into the predominant seller of ethanol at Argo, including in 90% of all MOC
2:19-cv-02240-CSB-EIL # 20 Page 7 of 29

2
transactions. (¶¶ 5, 73.) While ADM also occasionally bought ethanol at Argo, it never bought
during the MOC window to avoid influencing the Chicago Benchmark Price upwards. (¶¶ 5, 78-79.)
The continuation of the existing supply glut cannot explain this sudden, dramatic, and sustained
shift in ADM’s “competitive” behavior during the alleged manipulation period. Nor can ADM’s
ostensible “competitive advantage” derived from the proximity of its ethanol plants to Argo, which
were identically situated before November 2017, when ADM was the predominant buyer there.
Second, it is implausible that ADM was merely liquidating its existing stock for fear that
ethanol prices would drop further. Unlike its economically rational competitors that reduced output
in order to stabilize prices and prevent losses, ADM continued its production unabated for the
purpose of flooding Argo with ethanol that would be sold at ever-lower prices—prices that AOT
alleges were often below ADM’s variable cost of production. (¶¶ 2-5, 70-77.) At times, ADM even
sold more ethanol at Argo during the MOC window than it could deliver from its own plants,
requiring it to buy that ethanol from other parties at Argo at higher prices outside of the MOC
window. (¶¶ 5, 78-79.) Choosing to manufacture or buy more of a fungible commodity only to sell it
at a loss is not economically rational behavior, which explains why ADM was able to achieve a
monopoly on selling during the MOC window without much challenge from its profit-minded
competitors.
Third, had ADM actually been competing in an economically rational manner, it would have
sold its ethanol at terminals other than Argo or in private sales at higher prices than it received at
Argo. As detailed in AOT’s complaint, ADM’s shift to aggressive selling at Argo increased the
differences between prices at Argo and at three other major ethanol terminals to figures greater than
the cost of transporting ethanol there. (¶¶ 5, 80-89.) In the economic framework of “perfect
competition” that defines the fungible commodities markets, an economically rational actor would
not pass up an opportunity to earn risk-free profit by shifting sales to the other terminals. But ADM
2:19-cv-02240-CSB-EIL # 20 Page 8 of 29

3
chose to continue selling more ethanol at Argo for less than it could have received at the other
terminals on a cost-adjusted basis, causing the increased inter-terminal price differences to persist
throughout the alleged manipulation period.
Fourth, by November 2017, ADM had begun to amass large short positions in ethanol
futures tied to the Chicago Benchmark Price. (¶¶ 2, 5, 57, 60-61, 72.) Although it is true that ADM’s
natural hedging position as an ethanol producer was to be short ethanol, the sheer size of its
positions during the alleged manipulation period far eclipsed both its previous hedging activity and
its own ethanol production. At times, ADM bought enough futures in a given contract month to
“hedge” two to three times the ethanol it could possibly produce in that month. (¶¶ 5, 72.) ADM
was thus able to make more money from lower Chicago Benchmark Prices through derivatives than
it lost through its uneconomic ethanol sales at Argo. (¶¶ 2-5, 59-60.) ADM’s behavior at Argo was
economically rational only in the context of manipulation designed to maximize the profit
opportunity created by its outsized short positions in ethanol derivatives.
ADM’s alternative explanations for its behavior sidestep all of these allegations, which place
AOT’s complaint into a different universe of plausibility than the complaint dismissed in Twombly—
the case ADM makes the centerpiece of its dismissal argument. ADM also disregards several pages
of key allegations in arguing that AOT has not sufficiently alleged an artificial price or injury. AOT’s
complaint provides an empirically derived estimated range for not only the artificial decrease in the
Chicago Benchmark Price during the alleged manipulation period, but also the actual damage to
AOT’s specifically enumerated futures positions resulting from that artificial decrease. (¶¶ 80-89,
108-118.)
At this stage, the Court need not decide whether AOT’s interpretation of the alleged facts is
more probable than ADM’s. Taking all of AOT’s allegations as true, the Court need only confirm
that AOT’s complaint plausibly states a CEA manipulation claim. The Court should also reject
2:19-cv-02240-CSB-EIL # 20 Page 9 of 29

4
ADM’s premature attempt to carve from the case other derivatives that ADM claims AOT did not
trade, which is an argument properly addressed at class certification. ADM is wrong in any event: if
AOT proves its allegations, it will establish ADM’s liability for manipulation that would apply to all
derivatives tied to the Chicago Benchmark Price.
LEGAL STANDARD
Rule 8(a)(2) “requires only ‘a short and plain statement of the claim showing that the pleader
is entitled to relief,’ in order to ‘give the defendant fair notice of what the … claim is and the
grounds upon which it rests.’” Bell Atlantic v. Twombly, 550 U.S. 544, 555 (2007) (quoting Conley v.
Gibson, 355 U.S. 41, 47 (1957)). A claim must be plausible rather than merely conceivable or
speculative, Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009), meaning a complaint should include “enough
details about the subject-matter of the case to present a story that holds together.” Swanson v.
Citibank, N.A., 614 F.3d 400, 404 (7th Cir. 2010). On a motion to dismiss, the proper question to
ask when evaluating the sufficiency of a complaint is “could these things have happened, not did they
happen.” Id. In answering that question, a court must accept all well-pleaded factual allegations as
true. Twombly, 550 U.S. at 555-56.
ARGUMENT
1. AOT’s complaint easily satisfies Twombly’s “plausibility” standard.
In its principal argument, ADM misreads the “plausibility” standard established by Twombly
as a “probability” standard. The Supreme Court and the Seventh Circuit have repeatedly declined to
heighten the pleading standard in this way. ADM then compounds its error by arguing that AOT’s
allegations are analogous to those in Twombly, even though they are nothing alike.
2:19-cv-02240-CSB-EIL # 20 Page 10 of 29

5
1.1 ADM advocates for a “probability” pleading standard rejected by Twombly
and subsequent decisions.
ADM incorrectly asserts that, under Twombly, AOT’s allegations cannot plausibly support a
claim of manipulation if they can be viewed as equally or more “consistent with rational business
conduct” and “ordinary competition.” (Mem. at 1-2.) Twombly rejected this type of probability
assessment: “[A] well-pleaded complaint may proceed even if it strikes a savvy judge that actual
proof of those facts is improbable, and ‘that a recovery is very remote and unlikely.’” 544 U.S. at 556
(quoting Scheuer v. Rhodes, 416 U.S. 232, 236 (1974)). To make a claim for relief plausible, a complaint
need only allege “enough facts to raise a reasonable expectation that discovery will reveal evidence”
supporting the allegations. Twombly, 544 U.S. at 556.
Since Twombly, the Supreme Court has continued to reject a heightened “probability”
pleading standard. In Erickson v. Pardus, 551 U.S. 89, 93 (2007), the Court held that to satisfy
Twombly’s plausibility requirement, “[s]pecific facts are not necessary; the statement need only give
the defendant fair notice of what the … claim is and the grounds upon which it rests.” (Internal
quotations omitted.) In Iqbal, the Court held that Twombly’s “plausibility standard is not akin to a
‘probability requirement,’ but it asks for more than a sheer possibility that a defendant has acted
unlawfully.” 556 U.S. at 678.
The Seventh Circuit has followed the Supreme Court’s “plausibility not probability” guidance.
In Swanson, the court reversed the dismissal of a complaint and summarized pleading requirements in
light of Twombly, Erickson, and Iqbal:
‘Plausibility’ in this context does not imply that the district court should decide whose
version to believe or which version is more likely than not … . As we understand it,
the Court is saying instead that the plaintiff must give enough details about the subject-
matter of the case to present a story that holds together. In other words, the court will
ask itself could these things have happened, not did they happen. For cases governed
only by Rule 8, it is not necessary to stack up inferences side by side and allow the case
to go forward only if the plaintiff’s inferences seem more compelling than the
opposing inferences.
2:19-cv-02240-CSB-EIL # 20 Page 11 of 29

6
614 F.3d at 404.
ADM’s principal argument thus proceeds from an incorrect legal premise that improperly
invites the Court to weigh the strength of the parties’ competing inferences at the pleading stage.
The Court need only decide whether it is plausible that ADM’s aggressive selling at Argo during the
MOC window could have been designed to artificially reduce the Chicago Benchmark Price in order
to benefit ADM’s outsized derivatives positions.
1.2 AOT’s allegations are far stronger than the allegations in Twombly.
ADM asserts (Mem. at 7) that the “similarities between the present case and Twombly will
reward a closer look.” But a closer look reveals that there are no such similarities.
Twombly was an antitrust case under Section 1 of the Sherman Act, so the key issue at the
pleading stage was whether the plaintiffs had sufficiently alleged the existence of an agreement not
to compete. Twombly, 550 U.S. at 548-49. The defendants in that case were local telephone
companies that, after the breakup of AT&T, were awarded monopolies over certain geographic
areas. Id. at 549. They operated as legally sanctioned monopolies until Congress decided in 1996 to
encourage local competition by requiring the companies to “subsidize [new] competitors with their
own equipment at wholesale rates.” Id. at 566. The plaintiffs claimed that these companies conspired
with each other to restrain competition to keep the price of their services elevated. They did not
allege any facts supporting the existence of an actual agreement, but argued that an agreement could
be inferred from two types of parallel activity: (1) the local companies resisted new entrants into
their markets by creating various barriers; and (2) the local companies did not encroach into each
other’s geographic areas even though it might have been profitable to do so. Id. at 550-51.
The Supreme Court found that the first type of parallel activity did not support a plausible
inference of an actual agreement because each of the local companies had an independent economic
incentive to thwart new competitors to maximize their profits. “The economic incentive to resist
2:19-cv-02240-CSB-EIL # 20 Page 12 of 29

7
was powerful, but resisting competition is routine market conduct, and even if the [local companies]
flouted the 1996 Act in all the ways the plaintiffs allege, … there is no reason to infer that the
companies had agreed among themselves to do what was only natural anyway.” Id. at 566 (citations
omitted).
The Supreme Court found that the second type of parallel activity did not support a
plausible inference of an actual agreement because the local companies had simply continued
operating as local monopolies, as they had profitably done for many years before. “In a traditionally
unregulated industry with low barriers to entry, sparse competition among large firms dominating
separate geographical segments of the market could very well signify illegal agreement, but here we
have an obvious alternative explanation.” Id. at 567. The companies “were born in that world [of
monopoly], doubtless liked the world the way it was, and surely knew the adage about him who lives
by the sword. Hence, a natural explanation for the noncompetition alleged is that the former
Government-sanctioned monopolists were sitting tight, expecting their neighbors to do the same
thing.” Id. at 568.
Now compare the two failed theories in Twombly with the allegations in this case. The first
Twombly theory failed because the local telecom monopolies had independent, economically rational
incentives to resist competitors in order to safeguard their profits, which undermined any plausible
inference that their behavior resulted from an anticompetitive agreement. ADM’s actions at Argo,
by contrast, were economically irrational unless they were designed to juice the profits on ADM’s
outsized derivatives positions:
• During a time of falling prices and eroding (or negative) margins, ADM chose to sell more
ethanol at Argo at either no profit or a loss. (¶¶ 3-5, 71-77, 130.)
• Unlike its economically rational competitors that reduced output to decrease supply and
increase prices, ADM continued producing and aggressively selling ethanol during the MOC
window, including at prices below its variable cost of production. (¶¶ 3-5, 71-77, 130.)
2:19-cv-02240-CSB-EIL # 20 Page 13 of 29

8
• Instead of transporting its ethanol to other terminals to earn higher cost-adjusted revenues,
or selling at higher prices in non-terminal private sales, ADM achieved a monopoly in MOC
sales at lower cost-adjusted prices that it was simultaneously pushing down through its own
selling activity. (¶¶ 5, 71-73, 80-89, 130.)
• ADM at times even sold more ethanol during the MOC window than it could produce or
deliver, requiring it to source that ethanol from other parties at higher prices that guaranteed
losses for ADM. (¶¶ 5, 71-73, 78-79.)
Thus, the inference that ADM manipulated the Chicago Benchmark Price to artificially increase the
value of its outsized derivatives positions is plausible precisely because ADM’s activity at Argo was
so contrary to its rational economic incentives. That does not make AOT’s allegations analogous to
those in Twombly; it makes them diametrically opposite.
The second Twombly theory failed because no anticompetitive agreement could plausibly be
inferred from the local telecom companies simply continuing to operate as local monopolies. The
Court also found that the attractive business opportunities plaintiffs alleged existed in the geographic
areas of other local companies were speculative at best, as was the other companies’ ability to earn a
profit by attempting to compete in those areas. Id. at 568-69. By contrast, ADM did not simply
continue to operate as usual during the alleged manipulation period. Starting in November 2017,
ADM suddenly flipped from being the predominant buyer of ethanol at Argo, to being the
predominant seller when prices were lower, quickly achieving a monopoly (90%+) on sales during
the MOC window. (¶¶ 5, 71-77.) In other words, unlike in Twombly, ADM completely shifted its
“competitive” approach at the start and for the duration of the alleged manipulation period.
During the same period, ADM took massive short positions in derivatives that far exceeded
its previous hedging activity and its maximum monthly production capacity—sometimes by a factor
of two to three. (¶¶ 2, 5, 57, 60-61, 72.) Moreover, the additional revenue that ADM left on the table
by not selling its ethanol at the three other terminals (or in private, non-terminal sales) was real and
not speculative, as demonstrated by the sudden and persistent increase in the price differences
2:19-cv-02240-CSB-EIL # 20 Page 14 of 29

9
between Argo and the other terminals during the entire manipulation period. (¶¶ 80-89.) Also real
was the additional profit that ADM earned on its derivatives positions as a result of a decreasing
Chicago Benchmark Price. The natural inference is that ADM took these extraordinary and
seemingly uneconomic actions for a manipulative purpose.
By contrast, it is not plausible that ADM’s actions at Argo were “consistent with rational
business conduct” and “nothing other than ordinary competition.” ADM claims (Mem. at 1, 13) that
it “had a lot of ethanol to sell” at the start of the manipulation period, suggesting that falling prices
drove it to rationally liquidate its existing ethanol stock before prices fell further. Though that logic
might explain aggressive selling for a short period, it does not explain why ADM has continued
production unabated for nearly two years, increased its aggressive selling as it ceased to become
profitable, routinely sold more than it could itself supply at Argo, repeatedly sold at prices below its
own variable cost of production, and never sought to maximize its profits on physical sales by selling
at higher cost-adjusted prices at other terminals or in private, non-terminal sales. Continuing to
produce and sell a fungible commodity at a loss (including by buying that commodity at higher
prices to cover sales made at lower prices) is not a rational business strategy.
ADM’s ostensible competitive advantage derived from its proximity to Argo also does not
negate an inference of manipulation. Any such competitive advantage would have existed before
November 2017, when ADM was the predominant buyer at Argo at higher prices, so it cannot
explain ADM’s sudden shift to aggressively selling at lower prices during the MOC window in the
nearly two years that followed. A competitive advantage also does not explain why ADM left money
on the table by foregoing higher cost-adjusted revenues available at three other terminals or in
private, non-terminal sales. And perhaps most obviously, a competitive advantage cannot imbue
with economic rationality ADM’s decision to sell at Argo below its variable cost of production, or its
2:19-cv-02240-CSB-EIL # 20 Page 15 of 29

10
decision to sell so much ethanol that it had to fulfill its obligations at Argo by buying ethanol from
other producers at higher prices, thus locking in losses.
Besides, even if ADM’s alternative, non-manipulation-based explanations for its behavior
were plausible—or, indeed, more likely to be true—that would still not undermine the sufficiency of
AOT’s allegations to support a plausible inference of manipulation at the pleading stage. See Swanson,
614 F.3d at 404.
2. AOT has plausibly alleged a manipulation claim under the CEA.
The CEA provides a private cause of action for price manipulation. 7 U.S.C. § 25(a). Under
7 U.S.C. § 13(a)(2), it is unlawful for any trader to “manipulate or attempt to manipulate the price of
any commodity in interstate commerce, or for future delivery on or subject to the rules of any
registered entity.” The related regulation, 17 C.F.R. § 180.2, contains the same prohibition.
Courts have employed a four-part test to determine whether a plaintiff has adequately
pleaded price manipulation under 7 U.S.C. § 13(a)(2) and 17 C.F.R. § 180.2, requiring allegations that
“(1) the defendant[ ] possessed the ability to influence prices; (2) an artificial price existed; (3) the
defendant caused the artificial price; and (4) the defendant specifically intended to cause the artificial
price.” In re Dairy Farmers of America, Inc. Cheese Antitrust Litig., 801 F.3d 758, 764-65 (7th Cir. 2015).
AOT’s allegations satisfy all four requirements.
AOT’s complaint details ADM’s ability to influence the Chicago Benchmark Price, including
its large production capacity and the proximity of its ethanol plants to Argo. (¶¶ 2-3, 5, 22, 48-51,
59-69.) But the best evidence of ability to influence is that, almost overnight, ADM achieved a
monopoly (90-95%) on sales during the benchmark-setting MOC window—a monopoly that it has
maintained throughout the entire manipulation period. (¶¶ 5, 71-73, 80-89, 130.)
AOT’s complaint also alleges that ADM caused an artificial decrease in the Chicago
Benchmark Price, and how and why ADM did so. By continually flooding Argo with its ethanol and
2:19-cv-02240-CSB-EIL # 20 Page 16 of 29

11
routinely selling it at uneconomic prices, ADM pushed the price of ethanol lower than it would have
been under ordinary supply and demand dynamics. Moreover, by making low-priced offers during
the MOC window, ADM enticed buyers to enter into transactions that would be reflected in the
Chicago Benchmark Price. (¶¶ 61-69.) When that was not sufficient to trigger a sale, ADM made
sure to hit an even lower-priced bid that would likewise influence the Chicago Benchmark Price. Id.
While making low offers for a commodity and hitting open bids is not problematic or illegal in and
of itself, it becomes illegal when done for the improper purpose of influencing the value of a related
derivative. ADM strategically bunched its sales within the MOC window precisely so that those sales
would decrease the Chicago Benchmark Price and increase the value of its derivatives positions.
Indeed, ADM often sold more ethanol during the MOC window than it could itself supply, forcing
it to cover those obligations by buying ethanol exclusively outside of the MOC window to avoid
increasing the Chicago Benchmark Price and reducing the value of its derivatives. (¶¶ 5, 78-79.)
ADM’s conduct sent several important signals to ethanol buyers at Argo. First, buyers could
wait until the MOC window to get their ethanol because they knew that ADM would be offering
aggressively at that time of day. Second, buyers understood that they did not need to make truly
competitive bids to buy ethanol because a lack of executed transactions during the MOC window
would simply cause ADM to hit the open bids in the market that were priced lower than ADM’s
open offers. In other words, ADM’s repeated behavior sent a signal to buyers in the market that
they did not need to bid as high as they might otherwise be willing to pay in order to transact. ADM
would eventually sell them ethanol for less, and rational buyers generally prefer not to pay more than
they know they have to.
This combination of reducing offer prices and hitting even lower-priced bids during the
MOC window had the effect of driving Argo ethanol prices lower, both inside and outside the MOC
window. And that is precisely why an ethanol producer with 10% U.S. market share was able to
2:19-cv-02240-CSB-EIL # 20 Page 17 of 29

12
continuously capture 90-95% of MOC sales for nearly two straight years. Buyers simply waited for
ADM to lower prices, while ADM’s economically rational competitors cut production volumes and
largely abandoned Argo, especially during the MOC window.
The fact that ADM’s competitors also occasionally engaged in MOC sales, as ADM points
out (Mem. at 13), does not negate this economic logic. Other sellers may have had their own
idiosyncratic reasons to sell at the artificially low prices created by ADM—e.g., due to an actual
desire to liquidate stock to prevent further losses caused by ADM’s manipulation, or due to being
forced to close or settle another time-sensitive position. But combined, all of these other sellers
captured only 10% or less of MOC sales during the manipulation period. And when others
occasionally sold in a market where ADM had already created artificially depressed prices, ADM still
accomplished its goal of having low-priced transactions exert their influence on the Chicago
Benchmark Price.
Beyond mere economic theory, AOT’s complaint empirically derives an estimate of the
artificial price reduction caused by ADM’s aggressive and uneconomic selling. It does so by
comparing the differences between Argo prices and prices at three other major ethanol terminals
both before and during the manipulation period. (¶¶ 80-89.) In a perfectly competitive market for
commodities, the difference in the price of an identical product at different locations is explained
almost entirely by the cost of transporting that product. As AOT’s complaint shows, the differences
between ethanol prices at Argo and the three other terminals suddenly increased beginning in
November 2017 without a concomitant increase in transportation costs, and that increase persisted
throughout the manipulation period. (¶¶ 80-89.) AOT’s empirical analysis estimates this increased
inter-terminal price differential—which serves as a proxy for the artificial price decrease caused by
ADM’s manipulation—to be roughly 5.5 to 6.6 cents per gallon. Id.
2:19-cv-02240-CSB-EIL # 20 Page 18 of 29

13
The final element of a manipulation claim under the CEA is the defendant’s intent to create
an artificial price, and AOT has alleged numerous facts supporting that element. AOT alleges that
ADM amassed outsized derivatives positions in futures tied to the Chicago Benchmark Price that
stood to benefit from lower-priced transactions during the MOC window at Argo. (¶¶ 2, 5, 57, 60-
61, 72.) It is implausible that ADM took these positions for legitimate hedging purposes, because
they “hedged” two to three times more ethanol than ADM had the capacity to produce. (¶¶ 5, 72.)
This massive leverage incentivized and allowed ADM to make uneconomic sales at Argo because
the lost revenue on those sales was far outpaced by the gains in ADM’s futures positions. AOT’s
complaint even identifies the two employees that conceived and executed this manipulative
scheme—Ray Bradbury and Adam Kuffel. (¶¶ 2, 61, 103.)
Faced with similar allegations, courts have found that plaintiffs plausibly alleged
manipulation under the CEA. For example, in Ploss v. Kraft Foods Group, Inc., 197 F. Supp. 3d 1037
(N.D. Ill. 2016)—a case ADM relies on—the court held that market manipulation had been
adequately alleged where the plaintiff provided “specific details about the scheme” by the defendant
to engage in uneconomic transactions seemingly inconsistent with its business needs, which in turn
disproportionately benefitted aggressive derivatives positions that the defendant had simultaneously
taken. Id. at 1058-59. Like the plaintiffs in Ploss, AOT has adequately pleaded facts showing how
ADM’s acquisition of disproportionately large futures positions was “willfully combined” with
ADM’s uneconomic sales in the physical ethanol market at Argo to send “a false signal through its
market behavior.” Id. at 1059.
ADM cannot credibly argue that the totality of these allegations is insufficient to plausibly
infer manipulation, so it instead misconstrues certain of AOT’s allegations in isolation. For example,
ADM claims that AOT has alleged manipulation on only two trading days, which is plainly incorrect.
AOT has alleged daily and persistent manipulation starting in November 2017 and continuing
2:19-cv-02240-CSB-EIL # 20 Page 19 of 29

14
through the date of the complaint. The two days of MOC trading activity are included only for
purposes of illustration. Indeed, Platts does not release granular, daily MOC trading data to the
general public—and specifically not for litigation purposes—so AOT used as mere exemplars the
data from two days that happened to be available. ADM’s spin on these exemplars is incredibly
strained given AOT’s repeated allegations of continued manipulation lasting nearly two years, of the
fact that ADM was reported to be the seller in 90% or more of all MOC transactions throughout the
manipulation period, and of the increase in the inter-terminal ethanol price differences (a proxy for
price artificiality) that has persisted from November 2017 through the filing of this lawsuit.
3. AOT has plausibly alleged that it was injured as a result of ADM’s manipulation.
To plead actual damages under the CEA, a plaintiff need only allege that “it purchased one
or more of the contracts at issue during the class period and was injured as a result of defendants’
manipulative conduct.” In re Amaranth Nat. Gas Commodities Litig., 269 F.R.D. 366, 380 n.97
(S.D.N.Y. 2010). The pleading requirement for injury is minimal in cases such as this one, because
where “plaintiffs transacted at artificial prices, injury may be presumed.” Id. at 380 (footnote
omitted).
AOT’s allegations satisfy this minimal pleading requirement. First, AOT alleges that ADM’s
downward manipulation of ethanol prices at Argo began in November 2017 and persisted at least
until the complaint was filed in September 2019. (¶ 5.) Second, AOT alleges that it purchased
multiple long ethanol derivative contracts during the period where ADM was persistently
manipulating ethanol prices downward to benefit its own outsized short futures positions. (¶¶ 108–
118.) Third, AOT alleges that during the manipulation period, such contracts traded at artificial
prices that were between 5.5 and 6.6 cents lower than the but-for price absent manipulation. (¶ 111.)
And finally, AOT shows over a 19-month period precisely how long or short AOT was in Chicago
Ethanol (Platts) Futures contracts. (¶ 110.) It then multiplies AOT’s net long position by the
2:19-cv-02240-CSB-EIL # 20 Page 20 of 29

15
artificial decrease in price to reach a preliminary damages estimate between $5,271,420 and
$6,325,704. (¶ 112.) These allegations of injury are more than sufficient at the pleading stage.
Other courts considering the CEA’s injury requirement have found it satisfied by far less-
detailed allegations. In Kohen v. Pacific Investment Management Co. LLC (“PIMCO I”), 244 F.R.D. 469
(N.D. Ill. 2007), aff’d 571 F.3d 672 (7th Cir. 2009), the plaintiffs alleged that the defendants
manipulated the price of Treasury note futures upwards. Id. at 472. In their complaint, the plaintiffs
alleged only that they “held short positions in the June contract during the Class Period and
purchased back such June contracts at the artificially high prices caused by PIMCO’s highly unusual
behavior,” and that this “unlawful conduct caused damages to plaintiffs.” PIMCO I, 2006 WL
1773090, First Am. Consolidated Class Action Compl. at ¶ 13. The complaint contained no
estimation of the plaintiffs’ actual damages and no estimation of the differential created by the
artificial price. Nevertheless, the court found that the plaintiffs “ha[d] standing to sue under … § 22
of the CEA” because they “alleged that [they] purchased one or more June Contracts during the
class period and w[ere] injured as a result of defendants’ manipulative conduct.” PIMCO I, 244
F.R.D. at 474.
Similarly, in Amaranth, the court held that the plaintiffs pleaded injury under the CEA
without specifying the extent of their actual damages. In that case, the plaintiffs alleged that
defendants manipulated natural gas derivatives. Though the complaint included estimations of the
price differential created by the artificial price, it did not specify the extent to which the named
plaintiffs suffered actual damages. See Amaranth, 2008 WL 2841667, Corrected Consolidated Class
Action Compl. at ¶¶ 118–19, 144. Instead, the complaint stated that the plaintiffs “transacted at the
artificial prices caused by the Amaranth Defendants” and were “also caused to suffer losses and
injury.” Id. ¶¶ 17–19; accord ¶¶ 20–21. Indeed, the plaintiffs did not provide figures for their net
losses until the class certification stage of the litigation. See Amaranth, 269 F.R.D. at 375 nn. 40–44.
2:19-cv-02240-CSB-EIL # 20 Page 21 of 29

16
The Amaranth court nevertheless held that the plaintiffs had done enough to show that they
“suffered net losses caused by the … alleged manipulation,” and that since they “transacted at
artificial prices, injury may be presumed.” 269 F.R.D. at 379–80 (footnote omitted).
ADM attempts to sidestep AOT’s allegations of actual injury by claiming that AOT has
failed to allege that it traded on December 1, 2017 or August 3, 2018. (Mem. at 17.) But the
requirement that a plaintiff allege trading on specific days applies only to claims that a price was
“artificial for certain discrete days during the Class Period.” In re LIBOR-Based Fin. Instruments
Antitrust Litig., 962 F. Supp. 2d 606, 622 (S.D.N.Y. 2013). AOT does not allege that ADM
manipulated the Chicago Benchmark Price only on discrete days. Instead, as explained above, those
two dates were used in the complaint as examples to illustrate a persistent scheme that caused both
Argo ethanol and related derivatives to trade at artificial prices from November 2017 until the
complaint was filed. In “persistent suppression” cases such as this one, courts “d[o] not require
plaintiffs to allege the specific days on which they traded” the contract. Id.
ADM’s argument also misapprehends the nature of the specific derivatives contracts at issue
in this case. Under a diminishing balance contract like the Chicago Ethanol (Platts) Future, a portion
of the settlement value for the entire contract month is determined each day. (¶¶ 50-60.) AOT has
thus sufficiently alleged injury by virtue of holding long positions in December 2017 and August 2018
contracts that decayed pro-rata on each trading day—even if ADM manipulated the Chicago
Benchmark Price downward on some, but not all, days during those contract months.
Finally, ADM asserts that there is no plausible injury because AOT only speculates about
what damages it “may have suffered.” (Mem. at 18.) When read in its proper context (¶ 112),
however, this quotation does not cast doubt on the existence of AOT’s actual damages, which the
surrounding paragraphs lay out in detail. The word “may” instead qualifies only the magnitude of the
damages in light of the preliminary nature of the damages estimate at the pleading stage. This
2:19-cv-02240-CSB-EIL # 20 Page 22 of 29

17
language simply recognizes that the allegations in the complaint serve “only as a provisional estimate
of damages,” and that, “by the time all is said and done, the damages measure will likely become
more refined.” Abbott v. Lockheed Martin Corp., 725 F.3d 803, 808 (7th Cir. 2013). Both parties will
have ample opportunity to develop and contest damages models built on facts revealed through
discovery, but uncertainty about the precise magnitude of damages is not grounds for dismissal.
4. The Court should reject ADM’s unsupported attempt to chisel away at AOT’s class
allegations at the motion-to-dismiss stage.
ADM incorrectly argues that this Court should dismiss all claims for damages on two of the
three ethanol derivatives tied to the Chicago Benchmark Price that are within AOT’s proposed class
definition, but that ADM claims AOT did not trade. (Mem. at 19.) As an initial matter, AOT
nowhere alleged that it did not trade these derivatives; quite the opposite. See Compl. at ¶ 6 (alleging
that AOT “traded in such derivatives and suffered damages due to ADM’s manipulation”). That
AOT chose to focus on one type of derivative contract to plead its injury, which is all it was required
to do, does not amount to an assertion that it did not suffer damages on the two others.
ADM is also wrong to claim that, if AOT traded in only one type of derivative within its
proposed class definition, then it cannot pursue claims on behalf of traders in the two other
derivatives. All three derivatives were tied to the Chicago Benchmark Price. (¶ 30.) Thus, if AOT
establishes that ADM manipulated the Chicago Benchmark Price downward throughout the class
period, that finding of liability would apply equally to traders in all three derivatives. That the three
derivatives might have slightly different financial characteristics potentially relevant to the
appropriate measure of damages does not impact the commonality of ADM’s conduct to all putative
class members. Indeed, Rule 23(c)(4) specifically contemplates that “an action may be brought or
maintained as a class action with respect to particular issues,” and a defendant’s liability for conduct
common to the class is one such quintessential issue. See Butler v. Sears, Roebuck & Co., 727 F.3d 796,
2:19-cv-02240-CSB-EIL # 20 Page 23 of 29

18
800 (7th Cir. 2013) (“[A] class action limited to determining liability on a class-wide basis, with
separate hearings to determine—if liability is established—the damages of individual class members,
or homogeneous groups of class members, is permitted by Rule 23(c)(4) and will often be the
sensible way to proceed.”).
In any event, ADM’s argument is premature under Seventh Circuit law and exemplifies “the
problem inherent in conflating the standing inquiry with the inquiry under Rule 23 about the
suitability of a plaintiff to serve as a class representative.” Payton v. County of Kane, 308 F.3d 673, 677
(7th Cir. 2002). Even if ADM’s argument had merit, “the proper remedy for this shortcoming is not
dismissal of the … action, but rather an order denying class certification.” Id. Payton explicitly held
that courts in the Seventh Circuit must “consider issues of class certification prior to issues of [class]
standing” because “‘the class certification issues are … logically antecedent to Article III concerns’”
for class claims. Id. at 680 (quoting Ortiz v. Fibreboard Corp., 527 U.S. 815, 831 (1999)).
The sole case that ADM cites to support its argument, Dennis v. JPMorgan Chase & Co., 343 F.
Supp. 3d 122 (S.D.N.Y. 2018), actually undermines it. There, the named plaintiffs sought to
represent a class of all persons holding derivatives tied to the Bank Bill Swap Reference Rate
(“BBSW”) that were injured by the defendants’ BBSW manipulation. The plaintiffs brought claims
under the CEA as well other statutes and common law theories. Though the plaintiffs alleged that
they traded several BBSW-based derivatives, they apparently did not trade two particular derivatives
covered by the proposed class definition. Id. at 156-57. The court rejected defendants’ argument that
claims as to these derivatives should be dismissed and found that the “proof required for plaintiffs
to prevail on their federal claims,” including the CEA claims, “will be largely identical because … the
allegations underlying these claims are that defendants engaged in manipulative … transactions and
submitted false BBSW rates.” Id. at 159.
2:19-cv-02240-CSB-EIL # 20 Page 24 of 29

19
ADM disregards this portion of the opinion and instead cites a section related not to the
plaintiffs’ CEA claims, but rather the state law claims for breach of the implied covenant of good
faith and fair dealing and unjust enrichment. The Dennis court distinguished these claims from the
CEA claims because for the state-law claims, “plaintiff’s connection to the defendants is central to
the question of liability,” and the actual terms of the contracts between the absent class members
and the defendants would determine liability. Id. Since the named plaintiffs were not parties to these
contracts, they could not represent absent class members on state-law claims governed by these
contracts.
5. The CEA permits punitive damages.
ADM is likewise wrong about the CEA not allowing punitive damages. (Mem. at 19). The
one case ADM cites, Khalid Bin Talal v. E.F. Hutton, 720 F. Supp. 671 (N.D. Ill. 1989), predated the
1992 amendment to the CEA that specifically allowed for such damages. See Futures Trading
Practices Act of 1992, Pub. L. No. 102-546, § 222, 106 Stat 3590, 3617. The current version of 7
U.S.C. § 25(a)(3) provides that, “[i]n any action arising from a violation in the execution of an order
on the floor of a registered agent,” a plaintiff can recover actual damages under sub-paragraph (A),
and “where the violation is willful and intentional, punitive or exemplary damages equal to no more
than two times the amount of such actual damages” under sub-paragraph (B). Since AOT’s claims
implicate the execution of orders for futures and options on registered exchanges, and AOT alleges
that ADM’s conduct was willful and intentional, both actual damages and punitive damages are
available.
2:19-cv-02240-CSB-EIL # 20 Page 25 of 29

20
6. AOT can pursue all legal theories under the CEA that are consistent with its alleged
facts.
ADM finally contends that AOT cannot pursue claims under 7 U.S.C. §§ 6b(a) and 6c(a)
based upon ADM’s misreading of the CEA’s statutory and regulatory framework.1
But it is
unnecessary for the Court to resolve these issues now.
“Although it is common to draft complaints with multiple counts, each of which specifies a
single statute or legal rule, nothing in the Rules of Civil Procedure requires this. To the contrary, the
rules discourage it.” Bartholet v. Reishauer A.G. (Zürich), 953 F.2d 1073, 1078 (7th Cir. 1992). “Notice
is what counts. Not facts; not elements of ‘causes of action’; not legal theories.” Wilson v. Ryker, 451
F. App’x 588, 590 (7th Cir. 2011) (quoting Hefferman v. Bass, 467 F.3d 596, 600 (7th Cir. 2006)).
“Instead of asking whether the complaint points to the appropriate statute, a court should ask
whether relief is possible under any set of facts that could be established consistent with the
allegations.” Bartholet, 953 F.2d at 1078; accord Hall v. Nalco Co., 534 F.3d 644, 649 n.3 (7th Cir. 2008)
(“‘[A] complaint need not identify a legal theory, and specifying an incorrect theory is not fatal’ to a
plaintiff’s claim.”) (quoting Bartholet, 953 F.2d at 1078); Alden Mgmt. Servs., Inc. v. Chao, 532 F.3d 578,
582 (7th Cir. 2008) (“Courts don’t hold a party to its first legal theory.”).
Accordingly, if the Court finds that AOT has stated a plausible claim of manipulation under
the CEA, it can defer to a later stage any inquiry into how AOT’s alleged (and eventually proven)
facts fit into the various legal theories codified under the CEA. See Forseth v. Vill. of Sussex, 199 F.3d
363, 368 (7th Cir. 2000) (“Having specified the wrong done to him, a plaintiff may substitute one
legal theory for another without altering the complaint.”); O’Grady v. Vill. of Libertyville, 304 F.3d 719,
1
For example, contrary to ADM’s assertion (Mem. at 20) that there is no private cause of
action for violations of 7 U.S.C. § 6c(a), 7 U.S.C. § 25(a) creates a private cause of action against
“[a]ny person…who violates this chapter or who willfully aids, abets, counsels, induces, or procures
the commission of a violation of this chapter.” As the “chapter” in question is the CEA, and § 6c(a)
is within the CEA, AOT can pursue a private cause of action based on that provision.
2:19-cv-02240-CSB-EIL # 20 Page 26 of 29

21
723 (7th Cir. 2002) (noting that a party could advance a new legal theory at the summary judgment
stage as long as it was consistent with the allegations in the complaint).
CONCLUSION
AOT’s complaint plausibly alleges that ADM violated the CEA by engaging in a scheme to
manipulate the Chicago Benchmark Price. ADM has not demonstrated otherwise, and its motion to
dismiss should be denied in its entirety.
Dated: November 18, 2019 Respectfully submitted,
By: /s Michael E. Klenov
George A. Zelcs
John A. Libra
Chad E. Bell
Ryan Z. Cortazar
KOREIN TILLERY LLC
205 North Michigan Ave., Suite 1950
Chicago, IL 60601
Telephone: 312-641-9750
Facsimile: 312-641-9751
gzelcs@koreintillery.com
jlibra@koreintillery.com
cbell@koreintillery.com
rcortazar@koreintillery.com
Stephen M. Tillery
Michael E. Klenov
KOREIN TILLERY LLC
505 North 7th Street, Suite 3600
St. Louis, MO 63101
Telephone: 314-241-4844
Facsimile: 314-241-3525
stillery@koreintillery.com
mklenov@koreintillery.com
Attorneys for Plaintiff and the Proposed Class
2:19-cv-02240-CSB-EIL # 20 Page 27 of 29

CERTIFICATE OF COMPLIANCE WITH TYPE VOLUME LIMITATION
I hereby certify that the foregoing AOT’s Opposition to ADM’s Motion to Dismiss contains
6,958 words and 43,514 characters (including spaces), and therefore complies with Local Rule
7.1(B)(4).
George A. Zelcs
John A. Libra
Chad E. Bell
Ryan Z. Cortazar
KOREIN TILLERY LLC
Chicago, IL 60601
Telephone: 312-641-9750
Facsimile: 312-641-9751
Stephen M. Tillery
Michael E. Klenov
KOREIN TILLERY LLC
St. Louis, MO 63101
Telephone: 314-241-4844
Facsimile: 314-241-3525
2:19-cv-02240-CSB-EIL # 20 Page 28 of 29

CERTIFICATE OF SERVICE
I hereby certify that on November 18, 2019, I caused the foregoing AOT’s Opposition to
ADM’s Motion to Dismiss to be electronically served on all counsel of record by filing it with the
Clerk of Court using the CM/ECF system.
George A. Zelcs
John A. Libra
Chad E. Bell
Ryan Z. Cortazar
KOREIN TILLERY LLC
Chicago, IL 60601
Telephone: 312-641-9750
Facsimile: 312-641-9751
Stephen M. Tillery
Michael E. Klenov
KOREIN TILLERY LLC
St. Louis, MO 63101
Telephone: 314-241-4844
Facsimile: 314-241-3525
2:19-cv-02240-CSB-EIL # 20 Page 29 of 29

Adm aot memo in opposition

Empfohlen

Empfohlen

Weitere ähnliche Inhalte

Ähnlich wie Adm aot memo in opposition

Ähnlich wie Adm aot memo in opposition (20)

Mehr von GE 94

Mehr von GE 94 (20)

Kürzlich hochgeladen

Kürzlich hochgeladen (20)

Adm aot memo in opposition