On September 30th, a federal district court addressed the elements of a commodity futures manipulation lawsuit. Plaintiffs alleged defendants manipulated the markets for cheese and milk futures in violation of the Commodity Exchange Act. Denying defendant's motion for summary judgment the Court held that a plaintiff need not establish fraud, misrepresentation, or a violation of exchange rules to establish a market manipulation claim. Instead, the inquiry is whether the facts support a finding that defendant intended to subvert legitimate forces of supply and demand. Anderson v. Dairy Farmers of America, Inc.