On March 5th, the Second Circuit held that the district court properly dismissed antitrust lawsuits brought by plaintiffs representing the purchasers and issuers of auction-rate securities. Plaintiffs allege that the defendant banks conspired to stop supporting the ARS market, triggering the market's collapse, in an improper "boycott" or "refusal to deal" which violated Section 1 of the Sherman Act. The Court held that plaintiffs pleaded only parallel conduct in a market that was already declining. Plaintiffs' allegations of "common motive" only address the motive to support, not exit, the market and dismissal was therefore proper. Mayor and City Council of Baltimore, Maryland v. Citigroup, Inc.