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Bankruptcy Court Holds That SAFE Investors May Have Creditor Claims in Chapter 11

In In re Rhodium Encore LLC, the U.S. Bankruptcy Court for the Southern District of Texas ruled that holders of SAFEs should be treated as creditors because they possess creditor claims, not merely equity interests. The...more

Emphasizing Administrative Finality, Court Will Not Require the Reissuance of Checks Not Cashed by Prescribed Deadlines

Administrative deadlines in mass tort settlements are enforceable and binding­—courts will uphold them even when millions of dollars are at stake and international claimants are involved. Electronic notification through...more

Bankruptcy Court Ruling Highlights Circuit Split on Franchise Agreements

The California decision reinforces a strict approach to assumption of franchise agreements, underscoring potential roadblocks for franchisee reorganizations. Even where a debtor is not assigning a franchise agreement,...more

Time Approach Applied to Cap Rent Claim in Century 21 Bankruptcy Cases

New York bankruptcy court breaks with precedent and endorses time approach for calculating lease termination damages over rent amount approach, resulting in smaller claims for landlords. Time approach limits, and often...more

Acquiring a Distressed Business in the United States: Key Issues for Prospective Buyers

Prospective buyers should prepare to take advantage of opportunities to acquire distressed businesses, as we are likely to see an uptick in distressed M&A soon. Prospective buyers seeking first-mover advantages should act...more

Landmark Ninth Circuit Decision on Post-Petition Interest for Unimpaired Creditors of a Solvent Chapter 11 Debtor

The Ninth Circuit became the first circuit-level court to address the correct rate of interest for unimpaired, unsecured creditors of a solvent chapter 11 debtor. The Ninth Circuit held that the common law “solvent debtor...more

Post-Petition Payment for Pre-Petition Delivery of Goods under Section 503(b)(9) Does Not Reduce Creditor’s Subsequent New Value...

An Eleventh Circuit Court of Appeals’ decision permits a creditor both to be paid in full under Bankruptcy Code section 503(b)(9) for goods delivered within 20 days before commencement of a bankruptcy case, and to use the...more

A Warning to Contract Counterparties: A Debtor Can Sell Your Fully Performed Contract Without Curing Defaults and Paying Your...

A decision by the Third Circuit Court of Appeals serves as a stark reminder that the sale (assignment) of a contract in bankruptcy does not always require full payment of the non-debtor counterparty’s claim. Debtors must...more

My Brother’s Keeper: When Do Minority Stockholders Risk Being Considered “Controllers” of a Delaware Corporation?

Recent Delaware cases have clarified that minority stockholders merely rolling over shares alongside an independent and unrelated controlling stockholder do not form a control group in most cases—the controlling stockholder...more

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