HTG Capital Partners, LLC, filed a lawsuit in a federal court in Chicago against unnamed defendants, claiming they engaged in spoofing and manipulation of US Treasury futures contracts traded on the Chicago Board of Trade on “thousands of instances" during 2013 and 2014. According to HTG’s complaint, which formally named “John Doe(s)” as defendants, the firm seeks through discovery to identify the precise persons responsible for the alleged wrongful conduct. Once learning these identities, which HTG claims are currently known by the CBoT or Chicago Mercantile Exchange Group, the firm proposes to amend its lawsuit to name precise parties. HTG claims that the defendants’ wrongful conduct comprised three phases: (1) placing orders on one side of the market they intended to cancel before execution for the purpose of inducing other orders by third parties on the same side of the market; (2) cancelling their own orders; and (3) “virtually simultaneously” with their cancellations, placing orders on the opposite side of the market to trade against the orders they initially induced third parties to place (conduct sometimes referred to as “flipping”). In bringing this case, HTG relied on two relatively new provisions of law enacted as part of the adoption of the Dodd-Frank Wall Street Reform and Consumer Protection Act—the prohibition against disruptive trading practices and the prohibition against engaging in any manipulative or deceptive device or contrivance.