Dan Brockett, a partner in the New York office of Quinn Emanuel Urquhart & Sullivan LLP, said plaintiffs that didn't buy securities directly from lenders who set Libor rates when the benchmark was being manipulated still have a valid claim because the banks allegedly did have a direct impact on the pricing of securities and it was foreseeable that their actions would have an impact on holdings.

"We still think there's a respectable claim by a third party investor that didn't buy securities directly from one of the Libor banks under federal securities law and common law fraud," Brockett said.

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