Laydon v. Coöperatieve Rabobank U.A., 51 F.4th 476

Jeffrey Laydon, a U.S. resident, traded three‑month Euroyen TIBOR futures on the Chicago Mercantile Exchange during 2006–2011 and alleged loss from distorted benchmark rates.
He sued more than twenty banks and brokers, alleging a conspiracy to manipulate Yen‑LIBOR and Euroyen TIBOR by submitting false rates to benchmark setters (BBA in London; JBA in Tokyo).
The alleged manipulative submissions and most relevant conduct occurred on foreign trading desks and were transmitted to foreign benchmark administrators; some communications routed through or from U.S. servers were alleged but no submissions were sent to benchmark setters from within the U.S.
Laydon asserted claims under the Commodity Exchange Act (CEA), Section 1 of the Sherman Act (antitrust), and sought to add civil RICO claims based on wire fraud predicates.
The district court dismissed the CEA and antitrust claims and denied leave to add RICO; the Second Circuit affirmed, concluding the CEA claims were impermissibly extraterritorial, Laydon lacked antitrust standing, and RICO proximate causation was not adequately alleged.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CEA private‑action (§22) applies domestically despite foreign conduct	Laydon: trading on a U.S. exchange and domestic transaction make the CEA claim domestic	Defendants: the manipulative acts, benchmarks, and relevant markets were foreign, so CEA extraterritoriality bar applies	Court: Dismissed CEA claims — predominately foreign conduct; Section 22 has no clear extraterritorial intent and focus is on domestic transaction + domestic violation (affirmed)
Antitrust standing under AGC factors (efficient‑enforcer)	Laydon: injury from manipulated benchmark that affected his U.S. futures position gives standing	Defendants: Laydon is an indirect, speculative claimant (many intervening steps); direct victims exist; risk of speculative/duplicative damages	Court: No antitrust standing — injury indirect, speculative damages, apportionment/duplication problems; not an efficient enforcer (affirmed)
RICO proximate causation for civil RICO (wire fraud predicates)	Laydon: wire transmissions in furtherance of the scheme (some touching the U.S.) support RICO injury causation	Defendants: alleged RICO predicates are too remote from Laydon’s trading loss; many causal steps separate defendants’ conduct and his injury	Court: Denied leave to add RICO — proximate causation not alleged; injury not direct from predicate acts (affirmed)

Prime Int’l Trading, Ltd. v. BP P.L.C., 937 F.3d 94 (2d Cir. 2019) (CEA §22 claims impermissibly extraterritorial where derivatives peg to foreign asset and manipulative conduct occurred abroad)
RJR Nabisco, Inc. v. European Cmty., 579 U.S. 325 (U.S. 2016) (presumption against extraterritoriality and two‑step framework)
Morrison v. Nat’l Austl. Bank Ltd., 561 U.S. 247 (U.S. 2010) (statutes give no extraterritorial effect absent clear congressional intent)
Schwab Short‑Term Bond Mkt. Fund v. Lloyds Banking Grp. PLC, 22 F.4th 103 (2d Cir. 2021) (antitrust proximate cause/first‑step rule and efficient‑enforcer analysis)
Gelboim v. Bank of Am. Corp., 823 F.3d 759 (2d Cir. 2016) (antitrust standing framework and review standards)
Anza v. Ideal Steel Supply Corp., 547 U.S. 451 (U.S. 2006) (directness of injury for proximate cause in civil RICO/antitrust contexts)
Parkcentral Glob. Hub Ltd. v. Porsche Auto. Holdings SE, 763 F.3d 198 (2d Cir. 2014) (predominantly foreign claims are impermissibly extraterritorial)
Empire Merchs., LLC v. Reliable Churchill LLLP, 902 F.3d 132 (2d Cir. 2018) (RICO proximate causation requires direct link; courts rarely go beyond first step)