Motion Of Debtors For Entry Of Interim

Date: 2024-06-10

Summary

A motion filed June 10, 2024 as Doc 11 by the debtors in In re Vyaire Medical, Inc., et al., Case No. 24-11217, a Chapter 11 case in the U.S. Bankruptcy Court for the District of Delaware. The motion asks for interim and final orders authorizing the debtors to redact certain personally identifiable information of individuals, approving the form and manner of service of the notice of commencement, and granting related relief. It asks that Omni Agent Solutions, Inc., the proposed claims and noticing agent, serve the notice of commencement on the creditor matrix. Citing 11 U.S.C. § 107(c)(1) and state privacy laws, it seeks to redact individuals' home and email addresses from the creditor matrix and schedules and statements, citing comparable relief in other Delaware cases. The 28-page filing includes a proposed final order requiring an unredacted creditor matrix to be filed under seal.

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Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 1 of 28

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

)
In re: ) Chapter 11
)
VYAIRE MEDICAL, INC., et al., 1 ) Case No. 24-11217 (___)
)
Debtors. ) (Joint Administration Requested)
)

MOTION OF DEBTORS FOR ENTRY OF INTERIM
AND FINAL ORDERS (I) AUTHORIZING THE DEBTORS TO
REDACT CERTAIN PERSONALLY IDENTIFIABLE INFORMATION OF
INDIVIDUALS, (II) APPROVING THE FORM AND MANNER OF SERVICE
OF THE NOTICE OF COMMENCEMENT, AND (III) GRANTING RELATED RELIEF

The above-captioned debtors and debtors in possession (collectively, the “Debtors” and,

each, a “Debtor”) state as follows in support of this motion: 2

Relief Requested

1. The Debtors seek entry of interim and final orders, substantially in the forms

attached hereto as Exhibit A and Exhibit B (respectively, the “Interim Order” and the “Final

Order”): (a) authorizing the Debtors to redact certain personally identifiable information of

individuals; (b) approving the form and manner of service of the notice of commencement of these

chapter 11 cases; and (c) granting related relief. In addition, the Debtors request that the

1 The last four digits of Debtor Vyaire Medical, Inc.’s federal tax identification number are 6495. A complete list
of each of the Debtors in these chapter 11 cases and each such Debtor’s federal tax identification number may be
obtained on the website of the Debtors’ proposed claims and noticing agent at
https://omniagentsolutions.com/Vyaire. The location of Debtor Vyaire Medical, Inc.’s principal place of business
and the Debtors’ service address in these chapter 11 cases is 26125 North Riverwoods Boulevard, Mettawa,
Illinois, USA 60045.
2 A detailed description of the Debtors and their business, including the facts and circumstances giving rise to the
Debtors’ chapter 11 cases, is set forth in the Declaration of John Bibb, Group Chief Executive Officer of Vyaire
Medical, Inc., in Support of Chapter 11 Filing and First Day Motions (the “First Day Declaration”), filed
contemporaneously herewith and incorporated by reference herein. Capitalized terms used but not otherwise
defined herein shall have the meanings ascribed to them in the First Day Declaration.
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 2 of 28

Bankruptcy Court for the District of Delaware (the “Court”) schedule a final hearing

approximately 21 days after the Petition Date.

Jurisdiction and Venue

2. The United States District Court for the District of Delaware has jurisdiction over

this matter pursuant to 28 U.S.C. §1334, which was referred to the United States Bankruptcy Court

for the District of Delaware (the “Court”) under 28 U.S.C. § 157 and the Amended Standing Order

of Reference from the United States District Court for the District of Delaware, dated February 29,

2012. The Debtors confirm their consent, pursuant to rule 9013-1(f) of the Local Rules of

Bankruptcy Practice and Procedure of the United States Bankruptcy Court for the District of

Delaware (the “Local Rules”), to the entry of a final order by the Court in connection with this

motion to the extent that it is later determined that the Court, absent consent of the parties, cannot

enter final orders or judgments in connection herewith consistent with Article III of the United

States Constitution.

3. Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.

4. The statutory bases for the relief requested herein are sections 105(a), 107(c), and

521 of title 11 of the United States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), rules

1007, 2002, and 9007 of the Federal Rules of Bankruptcy Procedure (the “Bankruptcy Rules”),

and Local Rules 1001-1(c), 1007-1, 1007-2, 2002-1, 9013-1(m), and 9018-1(d).

Background

5. Vyaire Medical, Inc., together with its direct and indirect subsidiaries (collectively,

“Vyaire” or the “Company”), is a global company focused on developing products and providing

related services for the diagnosis, treatment, and monitoring of various cardiology, pulmonology,

and respiratory health conditions. With a 70-year history of pioneering breathing technology, the

integrated solutions offered by the Company help enable, enhance, and extend lives.

2
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Headquartered in Mettawa, Illinois, Vyaire operates approximately 27 offices and manufacturing

facilities, and employs approximately 950 individuals around the world. The Company has a

global reach, and Vyaire products are available in more than 100 countries. Its customers are the

hospitals, health centers, and private practice facilities delivering life-enhancing products and

services to patients every day.

6. On June 9, 2024 (the “Petition Date”), Vyaire Medical, Inc. and certain of its

subsidiaries filed a voluntary petition for relief under chapter 11 of the Bankruptcy Code. The

Debtors are operating their business and managing their property as debtors in possession pursuant

to sections 1107(a) and 1108 of the Bankruptcy Code. Concurrently with the filing of this motion,

the Debtors filed a motion requesting procedural consolidation and joint administration of these

chapter 11 cases pursuant to Bankruptcy Rule 1015(b). No request for the appointment of a trustee

or examiner has been made in these chapter 11 cases, and no official committees have been

appointed or designated.

Basis for Relief

I. Service of Notices to Creditors by the Claims and Noticing Agent Is Warranted.

7. Bankruptcy Rule 2002(a) provides, in relevant part, that “the clerk, or some other

person as the court may direct, shall give the debtor, the trustee, all creditors and indenture trustees

at least 21 days’ notice by mail of . . . the meeting of creditors under § 341 or § 1104(b) of the

[Bankruptcy] Code.” Fed. R. Bankr. P. 2002(a). Subsection (f) provides that notice of the order

for relief shall be sent by mail to all creditors. See Fed. R. Bankr. P. 2002(f).

8. The Debtors request that Omni Agent Solutions, Inc. (“Omni”), the proposed

claims and noticing agent (the “Claims and Noticing Agent”), undertake all mailings directed by

the Court or the United States Trustee for the District of Delaware (the “U.S. Trustee”) or as

required in section 342(a) of the Bankruptcy Code and Bankruptcy Rules 2002(a) and (f),

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Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 4 of 28

including serving the notice of commencement of these chapter 11 cases, substantially in the form

attached as Exhibit 1 to the Interim Order (the “Notice of Commencement”), on all parties listed

on the consolidated list of creditors (the “Creditor Matrix”) to advise them of the meeting of

creditors under section 341 of the Bankruptcy Code. Service of the Notice of Commencement on

the Creditor Matrix will not only avoid confusion among creditors but will also prevent the

Debtors’ estates from incurring unnecessary costs associated with serving multiple notices to the

parties listed on the Debtors’ voluminous Creditor Matrix. Accordingly, service of the Notice of

Commencement is warranted.

9. The Debtors believe that using the Claims and Noticing Agent to promptly provide

notices to all applicable parties will maximize efficiency in administering these chapter 11 cases

and will ease administrative burdens that would otherwise fall upon the Court and the U.S. Trustee.

Additionally, the Claims and Noticing Agent will assist the Debtors in preparing creditor lists and

mailing initial notices, and, therefore, it is more efficient to authorize the Claims and Noticing

Agent to mail all notices, including the Notice of Commencement. Accordingly, Omni should

undertake such mailings.

VI. Redaction of Certain Confidential Information of Individuals Is Warranted.

10. Section 107(c)(1) of the Bankruptcy Code provides that the Court:

[F]or cause, may protect an individual, with respect to the following
types of information to the extent the court finds that disclosure of
such information would create undue risk of identity theft or other
unlawful injury to the individual or the individual’s property:

4
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 5 of 28

(A) Any means of identification . . . contained in a paper filed, or to
be filed, in a case under [the Bankruptcy Code].

(B) Other information contained in a paper described in
subparagraph (A).

11 U.S.C. § 107(c)(1).

11. In addition, privacy and data protection regulations have been enacted in key

jurisdictions in which the Debtors and their non-Debtor affiliates do business. For example, in

2018, the state of California enacted the California Consumer Privacy Act of 2018 (the “CCPA”),

which provides individuals domiciled in California the right to, among other things, request their

collected personal information, including postal addresses, be deleted by entities subject to the

regulation and opt out of the sale of personal information by such entities to third parties. Violators

risk injunctions and civil penalties of up to $2,500 for each violation and up to $7,500 for each

intentional violation. Cal. Civ. Code § 1798.155. The CCPA applies to all for-profit entities doing

business in California (“CCPA Entities”) that collect and process consumers’ personal data and

satisfy one of the following criteria: (i) annual gross revenue in excess of $25 million; (ii) buys,

shares, receives, or sells the personal information of more than 100,000 consumers, households,

or devices for commercial purposes; or (iii) receives 50% or more of their annual revenues from

selling consumers’ personal information. Cal. Civ. Code § 1798.140(d)(1). The Debtors likely

qualify as CCPA Entities because there are 3 facilities and operations located in California and the

Debtors’ annual gross revenue for 2023 was approximately $257 million. 3

12. It is appropriate to authorize the Debtors to redact from any paper filed or to be

3 See also the Virginia Consumer Data Protection Act, Va. Code §§ 59.1-575-59.1-585 (effective as of January 1,
2023), the Connecticut Act Concerning Personal Data Privacy and Online Monitoring, Public Act § 22-15
(effective as of July 1, 2023), the Colorado Privacy Act, Colo. Rec. Stat. § 6-1 (effective as of July 1, 2023), the
Utah Consumer Privacy Act, Utah Code § 13-61 (effective on December 31, 2023), the Florida Digital Bill of
Rights, Fla. Stat. § 501.701 (effective on July 1, 2024), the Texas Data Privacy and Security Act, Tex. Bus. &

5
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 6 of 28

filed with the Court in these chapter 11 cases, including the Creditor Matrix, the Debtors’

schedules of assets and liabilities, schedules of current income and expenditures, schedules of

executory contracts and unexpired leases, and statements of financial affairs as required by section

521 of the Bankruptcy Code and Bankruptcy Rule 1007 (the “Schedules and Statements”), and

any related affidavits of service, the home and email addresses of individuals—including the

Debtors’ current and former employees, independent contractors, and individual equity holders

because (i) such information can be used to perpetrate identity theft 4 and phishing scams or to

locate survivors of domestic violence, harassment, or stalking under section 107(c)(1) of the

Bankruptcy Code and (ii) disclosure risks violating other data and privacy laws and regulations,

thereby exposing the Debtors to potential civil liability and significant financial penalties.

13. Redaction is necessary to protect information that would create “undue risk of

identity theft or other unlawful injury to the individual or the individual’s property.”

11 U.S.C. § 107(c)(1). The risk in relation to section 107(c)(1) of the Bankruptcy Code is real and

not merely speculative. In at least one chapter 11 case in Delaware, the abusive former partner of

Com. Code Ann. § 541 (effective on July 1, 2024), the Oregon Consumer Privacy Act, Or. Rev. Stat. § 1.13
(effective as of July 1, 2024), the Montana Consumer Data Privacy Act, Mont. Code Ann. § 35 (effective on
October 1, 2024), the Delaware Personal Data Privacy Act, Del. Code Ann. tit. 6 § 12D-102 (effective as of
January 1, 2025), the Iowa Data Privacy Law, Iowa Code § 715D.1 (effective on January 1, 2025), the New
Hampshire Privacy Law, N.H. Rev. Stat. § 507-H:1 (effective on January 1, 2025), the Tennessee Information
Protection Act, Tenn. Code Ann. § 47-18 (effective on July 1, 2025), the New Jersey Data Privacy Act , N.J. Rev.
Stat. § 56:1 (effective on January 15, 2025), and the Indiana Data Privacy Law, Ind. Code § 24-15 (effective on
January 1, 2026).
4 See In re Endo Int’l PLC, No. 22-22549 (JLG), 2022 WL 16640880, at *7, 11, 12 (Bankr. S.D.N.Y. Nov. 2, 2022)
(taking “judicial notice of the fact that identity theft is a world-wide problem,” recognizing that the right of public
access to judicial records “is not absolute,” and authorizing the debtors to redact the names, home addresses, and
email addresses of certain litigation claimants located in the US, EU, UK, and Australia from any paper filed with
that court and/or otherwise made publicly available by the debtors and the claims and noticing agent thereof); see
also In re Genesis Glob. Holdco, LLC, 652 B.R. 618, 636–37 (Bankr. S.D.N.Y. 2023) (quoting Endo and finding
that “[h]ome addresses fall within that category of information, as it is taken as a ‘given’ that they constitute
personally identifiable information that is vital information to perpetrators of identity theft, stalking and intimate
partner violence alike, and that publishing such information facilitates an identity thief’s search for data and a
stalker’s or abuser’s ability to find his or her target”). Id. at 635, 637.

6
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 7 of 28

a debtor’s employee used the publicly accessible creditor and employee information filed in the

chapter 11 case to track the employee at her new address that had not been publicly available until

then, forcing the employee to change addresses again. 5 More recently, in a chapter 11 case in the

Southern District of New York, at least twelve phishing scams have been uncovered. 6 These

incidents targeted individuals whose names were publicized in the creditor matrix, including one

in which scammers modified a court order and sent it to individuals whose names were disclosed,

two where scammers posed as associates of debtors’ counsel using fake email accounts purportedly

from debtors’ counsel and requested that individual creditors reply with their account and other

personal information, and another where scammers posed as the debtor’s claims agent and

requested the same information from individual creditors.

14. Courts in this jurisdiction have granted the relief requested herein in comparable

chapter 11 cases. See, e.g., In re Sientra, Inc., No. 24-10245 (JTD) (Bankr. D. Del. Apr. 9, 2024)

(authorizing the debtors to redact the names, home and email address of all individuals on the

creditor matrix, schedules and statements, affidavits of service and any other document filed with

the court); In re MVK FarmCo LLC, No. 23-11721 (LSS) (Bankr. D. Del. Nov. 15, 2023)

(authorizing the debtors to redact the home and email addresses of individuals from the creditor

matrix, schedules and statements, affidavits of service, and any other documents filed with the

court); In re Yellow Corp., No. 23-11069 (CTG) (Bankr. D. Del. Sept. 13, 2023) (same); In re

Lannett Co., No. 23-10559 (JKS) (Bankr. D. Del. Aug. 11, 2023) (same); In re PGX Holdings,

5 The incident, which took place during the first Charming Charlie chapter 11 proceedings in 2017, is described in
the “creditor matrix motion” filed in Charming Charlie Holdings Inc., No. 19-11534 (CSS) (Bankr. D. Del.
July 11, 2019), Docket No. 4.
6 See In re Celsius Network LLC, No. 22-10964 (MG), Docket Nos. 1527, 1681, 1904, 1992, 2082, 2896, 3121,
3251, 3422, 3722, 3932, and 4070.

7
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 8 of 28

Inc., No. 23-10718 (CTG) (Bankr. D. Del. July 19, 2023) (same); In re SiO2 Med. Prods., Inc.,

No. 23-10366 (JTD) (Bankr. D. Del. June 15, 2023) (same).

15. In addition to granting the requested relief, courts in this district have also

expounded on the importance of authorizing debtors to redact individual creditors’ personally

identifiable information, including home addresses in particular. See Hr’g Tr. at 21:13–21,

In re Dex Media, Inc., No. 16-11200 (KG) (Bankr. D. Del. May 18, 2016) (“THE

COURT: . . . Well, I think, that in the present day, with the abuse of private information, that these

addresses ought to be redacted, and so . . . I just think that individuals whose only position is to

have been former employees, for example, ought not to have their home addresses listed publicly.

I think that . . . creates a possibility of abuse . . . .”).

16. In Art Van Furniture, in overruling the objection of the U.S. Trustee to the same

redaction relief proposed here, Chief Judge Sontchi noted that the proposed redaction is not a

“burden of proof” issue so “much as a common sense issue.” Hr’g Tr. at 25:6–7, In re Art Van

Furniture, LLC, No. 20-10553 (CSS) (Bankr. D. Del. Mar. 10, 2020). 7 Judge Sontchi found that

“at this point and given the risks associated with having any kind of private information out on the

internet, [redaction] has really become routine [and] I think obvious relief.” Id. at 25:13–16.

17. Similarly, in Clover Technologies, Judge Owens overruled the U.S. Trustee’s

objection, noting that “[t]o me it is common sense. I don’t need evidence that there is, at best, a

7 Similarly, Judge Sontchi previously overruled the U.S. Trustee’s objection to the redaction of individuals’
information and found that “it’s just plain common sense in 2019—soon-to-be 2020—to put as little information
out as possible about people’s personal lives to prevent [sic] scams . . . . [Identity theft] is a real-life issue, and,
of course, the issue of domestic violence is extremely important.” Hr’g Tr. at 48:20–22, 49:3–5, In re Anna
Holdings, Inc., No. 19-12551 (CSS) (Bankr. D. Del. Dec. 3, 2019). Notably, Judge Sontchi acknowledged that
“the world is very different from [the 1980s] when you and I started practice with the problems of identity theft”
and that his perspective had evolved in that he was not previously aware of “the dangers with this kind of
information becoming public.” Id. at 45:25–46:2, 47:22–24. The Debtors reserve the right to supplement the
record with respect to such risks insofar as they are not self-evident in this instance.

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risk of identity theft and worse a risk of personal injury from listing someone’s name and address

on the internet by way of the court’s electronic case filing system and, of course, the claims agent’s

website . . . . The court can completely avoid contributing to the risk by redacting the addresses.

And while there is, of course, an important right of access we routinely redact sensitive and

confidential information for corporate entities and redact individual’s home addresses.” Hr’g Tr.

at 24:21–25, 25:9–13, In re Clover Techs. Grp., LLC, No. 19-12680 (KBO) (Bankr. D. Del.

Jan. 22, 2020). And, in Forever 21, in overruling the U.S. Trustee’s objection, Judge Gross found

that “[w]e live in a new age in which the theft of personal identification is a real risk, as is injury

to persons who, for personal reasons, seek to have their addresses withheld.” Hr’g Tr. at 60:22–

25, In re Forever 21, Inc., No. 19-12122 (KG) (Bankr. D. Del. Dec. 19, 2019).

18. For these reasons, the Debtors respectfully submit that cause exists to authorize the

Debtors to redact, pursuant to section 107(c)(1) of the Bankruptcy Code, and in compliance with

applicable privacy or data protection laws and regulations, the home and email addresses of

individuals listed on the Creditor Matrix, the Schedules and Statements, any related affidavits of

service, or any other document filed with the Court. Absent such relief, the Debtors (a) may be in

violation of applicable privacy or data protections laws and regulations, thereby exposing them to

severe monetary penalties that could threaten the Debtors’ operations during this sensitive stage

of their restructuring, (b) would unnecessarily render individuals more susceptible to identity theft

and phishing scams, and (c) could jeopardize the safety of current and former employees,

independent contractors, debtholders, and other individual creditors, who, unbeknownst to the

Debtors, are survivors of domestic violence, harassment, or stalking, by publishing their home

addresses without any advance notice or opportunity to opt out or take protective measures.

9
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 10 of 28

19. The Debtors propose to provide an unredacted version of the Creditor Matrix, the

Schedules and Statements, and any other filings redacted pursuant to the proposed Interim Order

and Final Order to (a) the Court, the U.S. Trustee, counsel to any official committee appointed in

these chapter 11 cases, and the Claims and Noticing Agent, and (b) any party in interest upon a

request to the Debtors (email is sufficient) or to the Court that is reasonably related to these

chapter 11 cases. In each case, this would be subject to a review of whether such disclosure, on a

case-by-case basis, would violate any obligation under any privacy or data protection law or

regulation. Nothing requested herein is intended to preclude a party in interest’s right to file a

motion requesting that the Court unseal the information redacted by the Interim Order or Final

Order. In addition, the Debtors will distribute as applicable any notices that are received at the

Debtors’ corporate headquarters and are intended for a current employee.

Compliance with Local Rule 9018-1(d)(iv)

20. To the best of the knowledge, information, and belief of the undersigned proposed

counsel to the Debtors, the documents that the Debtors are requesting to seal pursuant to the relief

requested in this motion do not contain information subject to the Confidentiality Rights of another

Holder of Confidentiality Rights (each, as defined in Local Rule 9018-1(d)(iii)).

Notice

21. The Debtors will provide notice of this motion to: (a) the U.S. Trustee; (b) the

holders of the 30 largest unsecured claims against the Debtors (on a consolidated basis); (c) the

office of the attorney general for each of the states in which the Debtors operate; (d) the United

States Attorney’s Office for the District of Delaware; (e) the Internal Revenue Service; (f) the

United States Securities and Exchange Commission; (g) counsel to the 1L Ad Hoc Group; (h) the

agent of the DIP Facility and counsel thereto; (i) the agent of the First Lien Credit Agreement and

counsel thereto; (j) the Second Lien Credit Agreement Agent and counsel thereto; (k) the agent of

10
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 11 of 28

the First Lien Notes and counsel thereto; and (l) any party that has requested notice pursuant to

Bankruptcy Rule 2002. As this motion is seeking “first day” relief, the Debtors will serve copies

of this motion and any order entered in respect to this motion as required by Local Rule 9013 1(m).

The Debtors submit that, in light of the nature of the relief requested, no other or further notice

need be given.

[Remainder of page intentionally left blank]

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Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 12 of 28

WHEREFORE, the Debtors request entry of Interim Order and Final Order, substantially

in the forms attached hereto as Exhibit A and Exhibit B, (a) granting the relief requested herein

and (b) granting such other relief as the Court deems appropriate under the circumstances.

Dated: June 10, 2024
Wilmington, Delaware

/s/ Patrick J. Reilly
COLE SCHOTZ P.C. KIRKLAND & ELLIS LLP
Patrick J. Reilley, Esq. (DE Bar No. 4451) KIRKLAND & ELLIS INTERNATIONAL LLP
500 Delaware Avenue, Suite 1410 Joshua A. Sussberg, P.C. (pro hac vice admission pending)
Wilmington, Delaware 19801 601 Lexington Ave
Telephone: (302) 652-3131 New York, New York 10022
Facsimile: (302) 652-3117 Telephone: (212) 446-4800
Email: preilley@coleschotz.com Facsimile: (212) 446-4900
Email: joshua.sussberg@kirkland.com
- and -
- and -
Michael D. Sirota, Esq. (pro hac vice admission pending)
Warren A. Usatine, Esq (pro hac vice admission pending) Spencer A. Winters, P.C. (pro hac vice admission pending)
Court Plaza North, 25 Main Street Yusuf U. Salloum (pro hac vice admission pending)
Hackensack, New Jersey 07601 333 West Wolf Point Plaza
Telephone: (201) 489-3000 Chicago, Illinois 60654
Facsimile: (201) 489-1536 Telephone: (312) 862-2000
Email: msirota@coleschotz.com Facsimile: (312) 862-2200
wusatine@coleschotz.com Email: spencer.winters@kirkland.com
yusuf.salloum@kirkland.com

Proposed Co-Counsel to the Debtors Proposed Co-Counsel to the Debtors
and Debtors in Possession and Debtors in Possession
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 13 of 28

Exhibit A

Proposed Interim Order
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 14 of 28

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

)
In re: ) Chapter 11
)
VYAIRE MEDICAL, INC., et al., 1 ) Case No. 24-11217 (___)
)
Debtors. ) (Joint Administration Requested)
) Re: Docket No. __

INTERIM ORDER (I) AUTHORIZING THE DEBTORS TO
REDACT CERTAIN PERSONALLY IDENTIFIABLE INFORMATION
OF INDIVIDUALS, (II) APPROVING THE FORM AND MANNER OF SERVICE
OF THE NOTICE OF COMMENCEMENT, AND (III) GRANTING RELATED RELIEF

Upon the motion (the “Motion”) 2 of the above-captioned debtors and debtors in possession

(collectively, the “Debtors”) for the entry of an interim order (this “Interim Order”), (a) authorizing

the Debtors to redact certain personally identifiable information of individuals; (b) approving the

form and manner of service of the notice of commencement of these chapter 11 cases;

related relief, all as more fully set forth in the Motion; and upon the First Day Declaration; and the

United States District Court for the District of Delaware has jurisdiction over this matter pursuant

to 28 U.S.C. § 1334, which was referred to the Court under 28 U.S.C. § 157 and the Amended

Standing Order of Reference from the United States District Court for the District of Delaware,

dated February 29, 2012; and this Court having found that this is a core proceeding pursuant to

28 U.S.C. § 157(b)(2); and this Court having found that venue of this proceeding and the Motion

in this district is proper pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that

the relief requested in the Motion is in the best interests of the Debtors’ estates, their creditors, and

other parties in interest; and this Court having found that the Debtors’ notice of the Motion and

opportunity for a hearing on the Motion were appropriate under the circumstances and no other

notice need be provided; and this Court having reviewed the Motion and having heard the

statements in support of the relief requested therein at a hearing before this Court (the “Hearing”);

and this Court having determined that the legal and factual bases set forth in the Motion and at the

Hearing establish just cause for the relief granted herein; and upon all of the proceedings had

before this Court; and after due deliberation and sufficient cause appearing therefor, it is HEREBY

ORDERED THAT:

1. The Motion is granted on an interim basis as set forth herein.

2. The final hearing (the “Final Hearing”) on the Motion shall be held on _________,

2024, at__:__ _.m., prevailing Eastern Time. Any objections or responses to entry of a final order

on the Motion shall be filed on or before 4:00 p.m., prevailing Eastern Time, on _________, 2024

and shall be served on: (a) the Debtors, 26125 North Riverwoods Boulevard, Mettawa, Illinois,

USA 60045, Attn.: Charles Braley (cbraley@alixpartners.com); (b) proposed co-counsel to the

Debtors (i) Kirkland & Ellis LLP, 601 Lexington Avenue, New York, New York 10022,

Attn.: Joshua A. Sussberg, P.C. (joshua.sussberg@kirkland.com), Chris Ceresa

(chris.ceresa@kirkland.com), and Tiffani Chanroo (tiffani.chanroo@kirkland.com), (ii) Kirkland

& Ellis LLP, 333 West Wolf Point Plaza, Chicago, Illinois, 60654, Attn.: Spencer A. Winters

(spencer.winters@kirkland.com) and Yusuf U. Salloum (yusuf.salloum@kirkland.com) (iii) Cole

Schotz P.C., 500 Delaware Avenue, Suite 1410, Wilmington, Delaware 19801, Attn.: Patrick J.

Reilley, Esq. (preilley@coleschotz.com), Stacy L. Newman (snewman@coleschotz.com),

2
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 16 of 28

Michael E. Fitzpatrick, Esq. (mfitzpatrick@coleschotz.com), and Jack M. Dougherty, Esq.

(jdougherty@coleschotz.com), and (iv) Cole Schotz P.C., Court Plaza North, 25 Main Street,

Hackensack, New Jersey 07601, Attn.: Michael D. Sirota, Esq. (msirota@coleschotz.com) and

Warren A. Usatine, Esq. (wusatine@coleschotz.com); (c) counsel to the 1L Ad Hoc Group,

(i) Gibson, Dunn & Crutcher LLP, 200 Park Avenue, New York, NY 10166-0193, Attn.: Scott J.

Greenberg (SGreenberg@gibsondunn.com), Jason Zachary Goldstein

(JGoldstein@gibsondunn.com), Joshua Brody (JBrody@gibsondunn.com), and Kevin Liang

(KLiang@gibsondunn.com) and (ii) Pachulski Stang Ziehl & Jones LLP, 919 North Market Street,

17th Floor, Wilmington, DE 19801, Attn.: Laura Davis Jones (ljones@pszjlaw.com); (d) the

United States Trustee, 844 King Street, Suite 2207, Lockbox 35, Wilmington, Delaware 19801,

Attn.: Benjamin A. Hackman (Benjamin.A.Hackman@usdoj.gov); and (e) any statutory

committee appointed in these chapter 11 cases.

3. As soon as practicable after entry of an order authorizing the engagement of Omni,

as Claims and Noticing Agent in these chapter 11 cases, the Debtors shall furnish to Omni a

consolidated Creditor Matrix.

4. The Debtors are authorized pursuant to section 107(c)(1) of the Bankruptcy Code,

to redact on the Creditor Matrix, the Schedules and Statements, affidavits of service, and any other

documents that the Debtors file with the Court, the home and email addresses of individuals. The

Debtors shall provide an unredacted version of the Creditor Matrix, the Schedules and Statements,

and any other filings redacted pursuant to this Interim Order to (a) the Court, the U.S. Trustee,

counsel to any official committee appointed in these chapter 11 cases, any subsequently appointed

chapter 7 or chapter 11 trustee, and the Claims and Noticing Agent, and (b) any party in interest

upon a request to the Debtors (email is sufficient) or to the Court that is reasonably related to these

3
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 17 of 28

chapter 11 cases, provided that any receiving party shall not transfer or otherwise provide such

unredacted document to any person or entity not party to the request. The Debtors shall inform

the U.S. Trustee promptly after denying any request for an unredacted document pursuant to this

Interim Order.

5. Nothing herein shall authorize the Debtors to redact any information from the list

of the holders of the 30 largest unsecured claims against the Debtors.

6. Notwithstanding anything to the contrary herein, the U.S. Trustee shall not be

required to redact any information from any notice of appointment of an official committee.

7. Nothing herein precludes a party in interest’s right to file a motion requesting that

the Court unseal the information redacted by this Interim Order.

8. The Debtors shall file a redacted version of the Creditor Matrix, Schedules and

Statements, or other document filed with the Court, as well as post it on Omni’s website.

9. For the avoidance of doubt, the Debtors shall file an unredacted Creditor Matrix

under seal with the Court.

10. Nothing in this Interim Order shall waive or otherwise limit the service of any

document upon or the provision of any notice to any individual whose personally identifiable

information is sealed or redacted pursuant to this Interim Order. Service of all documents and

notices upon individuals whose personally identifiable information is sealed or redacted pursuant

to this Interim Order shall be made to their residential addresses and confirmed in the

corresponding certificate of service.

11. To the extent a party in interest files a document on the docket in these chapter 11

cases that is required to be served on creditors whose information is under seal pursuant to this

Interim Order, such party in interest should contact counsel for the Debtors who shall work in good

4
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 18 of 28

faith, with the assistance of the Claims and Noticing Agent, to effectuate the service on such party’s

behalf.

12. All pleadings required to be served on individuals will be served at their

residential address.

13. The Notice of Commencement, substantially in the form attached hereto as

Exhibit 1, is approved. Service of the Notice of Commencement shall be deemed adequate and

sufficient notice of (a) the commencement of these chapter 11 cases and (b) the scheduling of the

meeting of creditors under section 341 of the Bankruptcy Code.

14. The Debtors, through their Claims and Noticing Agent, are authorized to serve all

pleadings and papers, including the Notice of Commencement, on all parties listed on the Creditor

Matrix (including via email if available).

15. Notice of the Motion as provided therein shall be deemed good and sufficient notice

of such Motion and the requirements of the Local Rules are satisfied by such notice.

16. Notwithstanding any Bankruptcy Rule to the contrary, the terms and conditions of

this Interim Order are immediately effective and enforceable upon entry.

17. The Debtors are authorized to take all actions necessary to effectuate the relief

granted in this Interim Order in accordance with the Motion.

18. This Court retains jurisdiction with respect to all matters arising from or related to

the implementation, interpretation, and enforcement of this Interim Order.

5
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 19 of 28

Exhibit 1

Notice of Commencement
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 20 of 28

Information to identify the case:
Debtor
Vyaire Medical, Inc., et al. EIN: 81-2596495
Name

United States Bankruptcy Court for the District of Delaware

Case number: 24-11217 ([●]) Date cases filed for chapter 11: June 9, 2024

Official Form 309F1 (For Corporations or Partnerships)

Notice of Chapter 11 Bankruptcy Case 10/20

For the debtor listed above, a case has been filed under chapter 11 of the Bankruptcy Code. An order for relief has
been entered.
This notice has important information about the case for creditors and debtors, including information about the
meeting of creditors and deadlines. Read both pages carefully.
The filing of the case imposed an automatic stay against most collection activities. This means that creditors generally may not take action to
collect debts from the debtor or the debtor’s property. For example, while the stay is in effect, creditors cannot sue, assert a deficiency,
repossess property, or otherwise try to collect from the debtor. Creditors cannot demand repayment from the debtor by mail, phone, or
otherwise. Creditors who violate the stay can be required to pay actual and punitive damages and attorney’s fees.
Confirmation of a chapter 11 plan may result in a discharge of debt. A creditor who wants to have a particular debt excepted from discharge
may be required to file a complaint in the bankruptcy clerk’s office within the deadline specified in this notice. (See line 11 below for more
information.)
To protect your rights, consult an attorney. All documents filed in the case may be inspected at the bankruptcy clerk’s office at the address
listed below or through PACER (Public Access to Court Electronic Records at https://pacer.uscourts.gov).

The staff of the bankruptcy clerk's office cannot give legal advice.

Do not file this notice with any proof of claim or other filing in the case.
Valid Picture ID is required for access to the J. Caleb Boggs Federal Building. Additionally, Debtor(s) must also present photo ID
plus original verification of his/her social security number to the Bankruptcy Trustee. If you do not have a photo ID and/or original
verification of your social security number, please contact the Office of the United States Trustee's (302−573−6491).

1. Debtor's full name: Vyaire Medical, Inc.

2. All other names used in the last 8 years: See Chart Below

Jointly Administered Cases Other Names (Last 8 Years) Case No. Tax ID No.

Vyaire Medical, Inc. Kingston Respiratory 101 Corp 24-11217 ([●]) 81-2596495

Bird Products Corporation 24-11218 ([●]) 33-0069580

Breathe US Holdco, Inc. 24-11219 ([●]) 92-2859526

Breathe US Holdings LP 24-11220 ([●]) 92-2878498

EME Medical, Inc. 24-11221 ([●]) 33-0894666

Revolutionary Medical Devices, Inc. 24-11222 ([●]) 47-3285028

SensorMedics Corporation 24-11223 ([●]) 33-0006779

VIASYS Holdings Inc. 24-11224 ([●]) 43-2055362

VM Finance Sub, LLC 24-11225 ([●]) 84-3883730

Vyaire Company 24-11226 ([●]) 32-0494861

Vyaire Finance B.V. 24-11227 ([●]) RSIN: 858615514

Vyaire Financial Holdings LLC 24-11228 ([●]) 84-3883575
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 21 of 28

Vyaire Holding Company Kingston Respiratory Corp. 24-11229 ([●]) 36-4835388

Vyaire Medical 202, Inc. CareFusion 202, Inc. 24-11230 ([●]) 04-3505871

Vyaire Medical 203, Inc. CareFusion 203, Inc. 24-11231 ([●]) 33-0737273

Vyaire Medical 205, Inc. CareFusion 205, Inc. 24-11232 ([●]) 36-3994160

Vyaire Medical 206, Inc. CareFusion 206, Inc. 24-11233 ([●]) 20-3233125

Vyaire Medical 211, Inc. CareFusion 211, Inc. 24-11234 ([●]) 16-1721349

Vyaire Medical BR LLC Kingston Respiratory BR LLC 24-11235 ([●]) 81-2564333

Vyaire Medical Capital LLC Kingston Respiratory Capital LLC 24-11236 ([●]) 81-2574742

Vyaire Medical Consumables LLC Kingston Respiratory Consumables
24-11237 ([●]) 81-2588610
LLC

Vyaire Medical International LLC Kingston Respiratory International
24-11238 ([●]) 81-2603646
LLC

Vyaire Medical LLC Kingston Respiratory 102 LLC 24-11239 ([●]) 37-1825258

Vyaire Medical Payroll LLC Kingston Respiratory Payroll LLC 24-11240 ([●]) 81-2643078

Vyaire Receivables LLC 24-11241 ([●]) 84-3478312

Vyaire Respiratory Diagnostics LLC 24-11242 ([●]) 99-0680820

Vyaire TSR MidCo, LLC 24-11243 ([●]) N/A

Vyaire TSR Sub, LLC 24-11244 ([●]) 86-1850847

3. Address: 26125 North Riverwoods Boulevard, Mettawa, Illinois, USA 60045

4. Debtors’ Attorneys KIRKLAND & ELLIS LLP
Name and KIRKLAND & ELLIS INTERNATIONAL LLP
Joshua A. Sussberg, P.C. (pro hac vice admission pending)
address
601 Lexington Avenue
New York, New York 10022
Cole Schotz P.C.
Patrick J. Reilley, Esq. and
500 Delaware Avenue
Suite 1410 KIRKLAND & ELLIS LLP
Wilmington, Delaware 19801 Contact phone: (302) 652-3131 KIRKLAND & ELLIS INTERNATIONAL LLP
Facsimile (302) 652-3117 Spencer A. Winters (pro hac vice admission pending)
Email: preilley@coleschotz.com Yusuf U. Salloum (pro hac vice admission pending)
333 West Wolf Point Plaza
and Chicago, Illinois 60654
Cole Schotz P.C. Email: joshua.sussberg@kirkland.com
Michael D. Sirota, Esq. (pro hac vice admission pending) spencer.winters@kirkland.com
Warren A. Usatine, Esq. (pro hac vice admission pending) yusuf.salloum@kirkland.com
Court Plaza North
25 Main Street
Hackensack, New Jersey 07601 Contact phone: (302) 652-3131
Facsimile (302) 652-3117
Email: msirota@coleschotz.com
wusatine@coleschotz.com

Debtors’ Claims and Noticing Agent Contact Phone:
(866) 956-2140 (toll free) or
If you have questions about this notice, please contact: +1 (818) 666-3635 (international)

Vyaire Medical, Inc. et al. Email: Vyaireinquiries@omniagnt.com
c/o Omni Agent Solutions, Inc.
5955 De Soto Avenue, Suite 100 Website: https://omniagentsolutions.com/Vyaire
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 22 of 28
Woodland Hills, CA 91367

5. Bankruptcy clerk's office

Documents in this case may be filed 824 N. Market Street, 3rd Hours open: Monday − Friday 8:00 AM − 4:00 PM
Floor Contact phone 302−252−2900
at this address. Wilmington, DE 19801
You may inspect all records filed in
this case at this office or online at
https://pacer.uscourts.gov.

6. Meeting of creditors [●][●], 2024, at [●] [a/p.m.] (ET) Location:

The debtor's representative must The meeting may be continued or The meeting of Creditors will
attend the meeting to be questioned adjourned to a later date. If so, be held by phone.
under oath. the date will be on the court Please call +[●] and use
Creditors may attend, but are not docket. access code [●] to join the
required to do so. meeting.

7. Proof of claim Deadline for filing proof of claim: Not yet set. If a deadline is set, the court will
deadline send you another notice.

A proof of claim is a signed statement describing a creditor’s claim. A proof of claim form may be obtained at
www.uscourts.gov or any bankruptcy clerk’s office.
Your claim will be allowed in the amount scheduled unless:
• your claim is designated as disputed, contingent, or unliquidated;
• you file a proof of claim in a different amount; or
• you receive another notice.

If your claim is not scheduled or if your claim is designated as disputed, contingent, or unliquidated, you must file
a proof of claim or you might not be paid on your claim and you might be unable to vote on a plan. You may file a
proof of claim even if your claim is scheduled.

You may review the schedules at the bankruptcy clerk’s office or online at https://pacer.uscourts.gov.

Secured creditors retain rights in their collateral regardless of whether they file a proof of claim. Filing a proof of
claim submits a creditor to the jurisdiction of the bankruptcy court, with consequences a lawyer can explain. For
example, a secured creditor who files a proof of claim may surrender important nonmonetary rights, including the
right to a jury trial.

8. Exception to discharge If § 523(c) applies to your claim and you seek to have it excepted from discharge, you must start a judicial
proceeding by filing a complaint by the deadline stated below.
Deadline
The bankruptcy clerk's office Deadline for filing the complaint: To be determined.
must receive a complaint and
any required filing fee by the
following deadline.

9. Creditors with a If you are a creditor receiving notice mailed to a foreign address, you may file a motion asking the court to
foreign address extend the deadlines in this notice. Consult an attorney familiar with United States bankruptcy law if you have
any questions about your rights in this case.

10. Filing a Chapter 11 Chapter 11 allows debtors to reorganize or liquidate according to a plan. A plan is not effective unless the court
bankruptcy case confirms it. You may receive a copy of the plan and a disclosure statement telling you about the plan, and you
may have the opportunity to vote on the plan. You will receive notice of the date of the confirmation hearing,
and you may object to confirmation of the plan and attend the confirmation hearing. Unless a trustee is serving,
the debtor will remain in possession of the property and may continue to operate its business.

11. Discharge of debts Confirmation of a chapter 11 plan may result in a discharge of debts, which may include all or part of your
debt. See 11 U.S.C. § 1141(d). A discharge means that creditors may never try to collect the debt from the
debtor except as provided in the plan. If you want to have a particular debt owed to you excepted from the
discharge and § 523(c) applies to your claim, you must start a judicial proceeding by filing a complaint and
paying the filing fee in the bankruptcy clerk's office by the deadline.

If you have questions about this notice, please contact the
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 23 of 28

Debtors’ Claims and Noticing Agent, Omni Agent Solutions, Inc.,
at (866) 956-2140 (toll free) or
+1 (818) 666-3635 (international),
or via email by submitting an inquiry at
Vyaireinquiries@omniagnt.com.

You may also find out more information at
https://omniagentsolutions.com/Vyaire

Official Form 309F1 (For Corporations or Partnerships) Notice of Chapter 11 Bankruptcy Case
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 24 of 28

Exhibit B

Proposed Final Order
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 25 of 28

IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

)
In re: ) Chapter 11
)
VYAIRE MEDICAL, INC., et al., 1 ) Case No. 24-11217 (___)
)
Debtors. ) (Joint Administration Requested)
) Re: Docket No. __

FINAL ORDER (I) AUTHORIZING
THE DEBTORS TO REDACT CERTAIN
PERSONALLY IDENTIFIABLE INFORMATION OF INDIVIDUALS,
(II) APPROVING THE FORM AND MANNER OF SERVICE OF THE
NOTICE OF COMMENCEMENT, AND (III) GRANTING RELATED RELIEF

Upon the motion (the “Motion”) 2 of the above-captioned debtors and debtors in possession

(collectively, the “Debtors”) for the entry of a final order (this “Final Order”), (a) authorizing the

Debtors to redact certain personally identifiable information of individuals; (b) approving the form

and manner of service in these chapter 11 cases; and (c) all as more fully set forth in the Motion;

and upon the First Day Declaration; and the United States District Court for the District of

Delaware has jurisdiction over this matter pursuant to 28 U.S.C. § 1334, which was referred to the

Court under 28 U.S.C. § 157 and the Amended Standing Order of Reference from the United States

District Court for the District of Delaware, dated February 29, 2012; and this Court having found

that this is a core proceeding pursuant to 28 U.S.C. § 157(b)(2); and this Court having found that

this Court may enter a final order consistent with Article III of the United States Constitution; and

this Court having found that venue of this proceeding and the Motion in this district is proper

pursuant to 28 U.S.C. §§ 1408 and 1409; and this Court having found that the relief requested in

the Motion is in the best interests of the Debtors’ estates, their creditors, and other parties in

interest; and this Court having found that the Debtors’ notice of the Motion and opportunity for a

hearing on the Motion were appropriate under the circumstances and no other notice need be

provided; and this Court having reviewed the Motion and having heard the statements in support

of the relief requested therein at a hearing before this Court (the “Hearing”); and this Court having

determined that the legal and factual bases set forth in the Motion and at the Hearing establish just

cause for the relief granted herein; and upon all of the proceedings had before this Court; and after

due deliberation and sufficient cause appearing therefor, it is HEREBY ORDERED THAT:

1. The Motion is granted on a final basis as set forth herein.

2. The Debtors are authorized, on a final basis, pursuant to section 107(c)(1) of the

Bankruptcy Code, to redact on the Creditor Matrix, the Schedules and Statements, affidavits of

service, and any other documents the Debtors file with the Court, the home and email addresses

of individuals. The Debtors shall provide an unredacted version of the Creditor Matrix, the

Schedules and Statements, and any other filings redacted pursuant to this Final Order to (a) the

Court, the U.S. Trustee, counsel to any official committee appointed in these chapter 11 cases, any

subsequently appointed chapter 7 or chapter 11 trustee, and the Claims and Noticing Agent, and

(b) any party in interest upon a request to the Debtors (email is sufficient) or to the Court that is

reasonably related to these chapter 11 cases, provided that any receiving party shall not transfer or

otherwise provide such unredacted document to any person or entity not party to the request. The

Debtors shall inform the U.S. Trustee promptly after denying any request for an unredacted

document pursuant to this Final Order.

2
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 27 of 28

3. Nothing herein shall authorize the Debtors to redact any information from the list

of the holders of the 30 largest unsecured claims against the Debtors.

4. Notwithstanding anything to the contrary herein, the U.S. Trustee shall not be

required to redact any information from any notice of appointment of an official committee.

5. Nothing herein precludes a party in interest’s right to file a motion requesting that

the Court unseal the information redacted by this Final Order.

6. The Debtors shall file a redacted version of the Creditor Matrix, Schedules and

Statements, or other document filed with the Court, as well as post it on Omni’s website.

7. For the avoidance of doubt, the Debtors shall file an unredacted Creditor Matrix

under seal with the Court.

8. Nothing in this Final Order shall waive or otherwise limit the service of any

document upon or the provision of any notice to any individual whose personally identifiable

information is sealed or redacted pursuant to this Final Order. Service of all documents and notices

upon individuals whose personally identifiable information is sealed or redacted pursuant to this

Final Order shall be made to their residential addresses and confirmed in the corresponding

certificate of service.

9. To the extent a party in interest files a document on the docket in these chapter 11

cases that is required to be served on creditors whose information is under seal pursuant to this

Final Order, such party in interest should contact counsel for the Debtors who shall work in good

faith, with the assistance of the Claims and Noticing Agent, to effectuate the service on such party’s

behalf.

3
Case 24-11217-BLS Doc 11 Filed 06/10/24 Page 28 of 28

10. All pleadings required to be served on individuals will be served at their

residential address.

11. Notice of the Motion as provided therein shall be deemed good and sufficient notice

of such Motion and the requirements of the Local Rules are satisfied by such notice.

12. The Debtors are authorized to take all actions necessary to effectuate the relief

granted in this Final Order in accordance with the Motion.

13. This Court retains jurisdiction with respect to all matters arising from or related to

the implementation, interpretation, and enforcement of this Final Order.

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Motion Of Debtors For Entry Of Interim

Summary

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