Notice of Reclamation Demand — Data-Modul, Inc., Vyaire Medical, Inc., Case No. 24-11217

Summary

DATA-MODUL, INC. (DATA), through counsel, filed a notice of reclamation demand in the Vyaire Medical, Inc., et al. case, citing 11 U.S.C. §§ 503 and 546. The notice states that the Goods were sold in DATA's course of business and delivered on credit terms to, and received by, the Debtors during the forty-five (45) days prior to the filing of the bankruptcy petitions, and that DATA believes the Debtors were insolvent when the Goods were delivered. It states the value of the Goods at issue is no less than $369,732.30 and that the formal reclamation demand letter was dated and delivered to the Debtor on June 27, 2024. The signature block names Frederick B. Rosner of The Rosner Law Group LLC, signed /s/.

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Full text

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IN THE UNITED STATES BANKRUPTCY COURT
FOR THE DISTRICT OF DELAWARE

In Re

VYAIRE MEDICAL, INC., et al., 1

           Debtors.

Chapter 11

Case No. 24-11217 (BLS)

(Jointly Administered)

NOTICE OF RECLAMATION DEMAND

PLEASE TAKE NOTICE that DATA-MODUL, INC. (“DATA”), by its undersigned
counsel, files this notice of delivery of a written demand, pursuant to 11 U.S.C. §§ 503 and 546
and applicable non-bankruptcy law, on the above-named debtor and debtor in possession (the
“Debtor”) and their counsel to reclaim certain assets (the “Goods”) that are subject to
reclamation. The Goods were sold in DATA’s course of business and delivered on credit terms
to, and actually received by, the Debtors during the forty-five (45) days prior to the filing of the
Debtors’ bankruptcy petitions. DATA believes that the Debtors were insolvent at the time they
received delivery of the Goods. The value of the Goods at issue in the demand is no less than
$369,732.30.

Annexed hereto and incorporated by reference herein as Exhibit “A,” is a copy of
DATA’s formal reclamation demand letter, dated June 27, 2024, which was delivered to the
Debtor on June 27, 2024 and which included documents related to the subject goods.

DATA reserves all of its rights, interests and remedies with respect to the Goods and 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,
Case 24-11217-BLS    Doc 124    Filed 06/27/24    Page 1 of 2

{00039192. }
2
Debtors, including filing an administration claim for goods received by the Debtors, a proof of
claim and amending this notice.
Dated: June 27, 2024

Wilmington, Delaware

THE ROSNER LAW GROUP LLC

/s/ Frederick B. Rosner

Frederick B. Rosner (DE 3995)
Zhao (Ruby) Liu (DE 6436)
824 N. Market Street, Suite 810
Wilmington, DE 19801
(302) 777-1111
rosner@teamrosner.com
liu@teamrsoner.com

and

MACCO & COREY, P.C.

Peter Corey, Esq.

USA 60045.

2950 Express Drive S.

Islandia, NY 11749

Tel: (631)549-7900 x.316

Email: pcorey@maccolaw.com

Counsel for DATA-MODUL, INC.
Case 24-11217-BLS    Doc 124    Filed 06/27/24    Page 2 of 2

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