In Allstate Ins. Co. v. Credit Suisse Sec. (USA) LLC, 42 Misc. 3d 1220[A], 2014 NY Slip Op 50106[U] (Sup. Ct. N.Y. Cnty. Jan. 24, 2014) the plaintiff Allstate purchased RMBS from defendant Credit Suisse which sustained massive losses over time. During the course of Allstate's investment, the ratings of the RMBS securities deteriorated to become utterly valueless. Allstate argued that the defendants manipulated the credit ratings in a manner similar to that alleged here under the "issuer pays model". The Rating Agencies rely upon the opinions point that "Claims based on credit ratings have been dismissed as inactionable absent an allegation that the rating agency did not believe that the ratings it assigned were supported by the factors considered". Id.