In late August 2019, a federal appeals court affirmed the dismissal of a lawsuit filed by Prime International Trading, Ltd. and other plaintiffs against BP P.L.C. and other defendants that claimed that defendants conspired to manipulate and manipulated the market for physical Brent crude and Brent futures contracts traded on the New York Mercantile Exchange and ICE Futures Europe through their bids, offers and transactions in the physical Brent market. Plaintiffs claimed that defendants’ conduct outside the United States – which was particularly aimed at impacting the daily “Dated Brent Assessment” – which effectively is the daily spot price for Brent crude – was also aimed at impacting Brent futures settlement prices which they claimed were largely influenced by the Dated Brent Assessment. The appeals court dismissed plaintiffs’ private right of action claims alleging manipulation under the Commodity Exchange Act claiming that the relevant provisions lacked a clear statement of extraterritorial application. According to the court, the “Plaintiffs have not pleaded a domestic application of the CEA by mere dint of the fact that – after a winding chain of foreign, intervening events – they purchased Brent Futures on exchanges. Were we to hold otherwise, the CEA would indeed ‘rule the world’.”