Vyaire - Motion to Extend Exclusivity — In re Vyaire Medical, Inc., et al., Case No. 24-11217 (BLS) (Jointly Administered)

Source document: Vyaire - Motion to Extend Exclusivity; document type: motion to extend exclusivity periods.

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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 (BLS)
)
Debtors.
)
(Jointly Administered)
)
)
Hearing Date: October 2, 2024, at 1:30 p.m. (ET)
)
Obj. Deadline: September 25, 2024, at 4:00 p.m. (ET)
MOTION OF DEBTORS FOR ENTRY
OF AN ORDER (I) EXTENDING THE DEBTORS’
 EXCLUSIVE PERIODS TO FILE A CHAPTER 11 PLAN AND
 SOLICIT ACCEPTANCES THEREOF PURSUANT TO SECTION 1121
OF THE BANKRUPTCY CODE AND (II) 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 an order, substantially in the form attached hereto as
Exhibit A (the “Proposed Order”), (a) extending the Debtors’ exclusive right to file a chapter 11
plan (the “Filing Exclusivity Period”) by ninety days through and including January 6, 20253, and
to solicit votes thereon (the “Solicitation Exclusivity Period” and, together with the Filing
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’ 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 Debtors’ Chapter 11 Petitions and First Day Motions [Docket No. 15]
(the “First Day Declaration”).  Capitalized terms used but not otherwise defined herein shall have the meanings
ascribed to them in the First Day Declaration or Bidding Procedure Order, as applicable.
3
Because 90 days from the current Filing Exclusivity Period deadline is January 5, 2025, which is a Sunday, the
Debtors request an extension through and including January 6, 2025.
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Exclusivity Period, the “Exclusivity Periods”) by ninety days through and including
March 6, 2025, in each case, without prejudice to the Debtors’ rights to seek further extensions of
each of the Exclusivity Periods, and (b) granting related relief.  Absent the relief requested herein,
the Filing Exclusivity Period will expire on October 7, 2024, and the Solicitation Exclusivity
Period will expire on December 6, 2024.
Preliminary Statement
2.
The Debtors request that the Court grant a 90-day extension of the Debtors’
exclusive right to file and solicit a plan.  Fewer than four months from the Petition Date, the
Debtors have made substantial progress in these chapter 11 cases.  In addition to customary “first
day relief” on the Petition Date, the Debtors filed a motion, pursuant to section 363 of the
Bankruptcy Code, seeking approval of certain proposed bidding procedures to conduct an
expedited sale process for all or substantially all the Debtors’ assets in their two business units,
ventilation and respiratory diagnostics.  The bidding procedures were approved by the Court on
July 11, 2024 [Docket No. 249] (the “Bidding Procedures Order”).  The Debtors’ sale process
resulted in two value-maximizing Sale Transactions (as defined below).
3.
After the filing of these cases, the Debtors worked tirelessly to continue the
marketing and sale process for the Debtors’ Ventilation Assets and Respiratory Diagnostics Assets.
After a full, fair and robust sale process, which included an auction for the Debtors’ Ventilation
Assets that lasted three days, the Debtors determined, in accordance with their business judgement
and the Bidding Procedures Order, that (a) the asset purchase agreement by and among ZOLL
Medical Corporation (“Zoll”) and the Debtors constituted the highest and best offer for certain
Ventilation Assets and (b) the asset purchase agreement by and among Trudell Medical Limited
(“Trudell”) and the Debtors constituted the highest and best offer for certain Respiratory
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Diagnostics Assets.  After notice and hearing, on September 4, 2024, the Court entered orders
approving both sale transactions (the “Sale Transactions”) [Docket Nos. 496˗97] (together,
the “Sale Orders”).  Since entry of the Sale Orders, the Debtors and their advisors have been
working diligently to effectuate and close each Sale Transaction, including identifying and
finalizing transition needs and negotiating the terms of transition services agreements.
4.
In parallel with, and now following, the marketing process, the Debtors are actively
engaged with their stakeholders in an effort to build consensus surrounding the treatment of certain
executory contracts and unexpired leases, including working to effectuate a smooth transition to
Zoll and Trudell.  The Debtors are also continuing to engage in good faith with the Official
Committee of Unsecured Creditors appointed in these chapter 11 cases (the “Committee”) in
discussions and information-sharing related to the sale process and developing a value-maximizing
chapter 11 plan.
5.
Despite the Debtors’ substantial progress to date, work remains to be done to bring
these chapter 11 cases to a close.  The Debtors remain focused on ensuring the success of the Sale
Transactions by fulfilling their obligations under the asset purchase agreements, yet, at the same
time, the Debtors have been discussing key terms of the Plan (as defined herein) with parties in
interest in these chapter 11 cases.  Contemporaneously herewith, the Debtors filed an initial
version of their Joint Chapter 11 Plan of Vyaire Medical, Inc. and Its Debtor Affiliates [Docket
No. 518] (as may be subsequently amended, supplemented, or modified from time to time, the
“Plan”) and Disclosure Statement for the Joint Chapter 11 Plan of Vyaire Medical, Inc. and Its
Debtor Affiliates [Docket No. 519] (as may be subsequently amended, supplemented, or modified
from time to time, the “Disclosure Statement”), along with a disclosure statement and solicitation
procedures motion [Docket No. 520] (the “Disclosure Statement Motion”).  The Debtors intend to
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utilize the omnibus hearing currently set for October 2, 2024, see Docket No. 494, for, inter alia,
the Court to consider approval of the Disclosure Statement and solicitation process on an interim
or conditional basis in accordance with the local rules.  Extension of each of the Exclusivity
Periods is critical to the Debtors’ efforts to obtain support of a value-maximizing plan without the
risk of substantial disruption and additional costs that could stem from the introduction of new
plans proposed by creditors seeking to advance their parochial interests.  Indeed, without the relief
requested herein, the current plan process would not be complete by the end of the current Filing
Exclusivity Period (i.e., October 7, 2024) based on the timeline set forth in the Disclosure
Statement Motion, and the introduction of another plan midway would threaten to derail the current
anticipated plan process, squandering the estate resources used in planning such process to-date.
Accordingly, by this motion, the Debtors are seeking a 90-day extension of the Exclusivity Periods
so that they may continue to diligently pursue an appropriate and value-maximizing resolution of
these chapter 11 cases without the distraction and cost of an exclusivity dispute.
6.
Furthermore, the Debtors have taken a number of key steps in these chapter 11
cases, including, among other things:

obtaining relief that has enabled the Debtors to continue their
operations and administration of these chapter 11 cases,
including obtaining approval of “first day” motions, “second
day” motions and retention applications;

negotiating and obtaining final approval for the Debtors’
debtor-in-possession financing facility and use of cash
collateral to address the Debtors’ liquidity needs in
chapter 11;

addressing questions, concerns and issues raised by
numerous employees, vendors, utility companies and other
parties in interest;

obtaining entry of an order setting the claims bar date to
facilitate the timely administration of their claims pool;
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
obtaining entry of the contract rejection procedures order;

continuing an extensive marketing process to identify,
develop and consummate value-maximizing transactions for
the Debtors’ assets, including holding a three-day auction in
connection with the sale of the Debtors’ Ventilation Assets,
which led to a significant increase in bid value to the benefit
of the estates;

obtaining entry of the Bidding Procedures Order;

obtaining entry of each of the Sale Orders, which included
certain modifications to the terms of the debtor in possession
financing, after a contested evidentiary hearing on
August 30, 2024;

negotiating and finalizing asset purchase agreements with
each of Zoll and Trudell;

working with their advisors to implement and effectuate the
Sale Transactions following entry of the Sale Orders,
including ongoing work to confer with each buyer and
parties in interest in connection with transition service needs
and the contract designation process;

responding to diligence requests from the Committee and
other key stakeholder groups; and

continuing discussions and negotiations with the Committee
and other key stakeholders regarding the terms of a
consensual resolution to these chapter 11 cases.
7.
Based on the current posture of these chapter 11 cases, the Debtors believe
sufficient cause exists to warrant an extension of the Exclusivity Periods.  Given the complexities
of these cases and the Debtors’ need to continue moving the chapter 11 cases forward, the Debtors’
ability to perform under the asset purchase agreements while building support for the terms of a
Plan and negotiating and finalizing the documents required for the Plan would be seriously
disrupted if another party were permitted to file a plan at this critical juncture.  An extension of
the Exclusivity Periods is in the best interests of the Debtors, their estates and all stakeholders, as
it will allow the Debtors to procure the best recovery for their creditors and help to ensure a
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successful conclusion to these chapter 11 cases.  A ninety-day extension is therefore appropriate
to protect the value and consensus fostered by the Debtors and their stakeholders and will not
prejudice any parties in interest.
8.
Accordingly, the Debtors seek a modest 90-day extension of the Exclusivity
Periods to maintain the exclusive right to file a plan until January 6, 2025, and solicit votes thereon
until March 6, 2025.  For all of the foregoing reasons and those set forth below, the Debtors
respectfully submit that a 90-day extension of exclusivity is appropriate in these circumstances,
and request that the Court approve extension of the Exclusivity Periods.
Jurisdiction and Venue
9.
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.
10.
Venue is proper pursuant to 28 U.S.C. §§ 1408 and 1409.
11.
The bases for the relief requested herein are section 1121(d) of title 11 of the United
States Code, 11 U.S.C. §§ 101–1532 (the “Bankruptcy Code”), Rule 9006 of the Federal Rules of
Bankruptcy Procedure (the “Bankruptcy Rules”) and Local Rule 9006-2.
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Background
12.
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.
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.
13.
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.  On June 11, 2024, the Court entered an
order authorizing the procedural consolidation and joint administration of these chapter 11 cases
pursuant to Bankruptcy Rule 1015(b) and Local Rule 1015-1.  See Docket No. 84.  No request for
the appointment of a trustee or examiner has been made in these chapter 11 cases.
14.
On June 26, 2024, the Office of the United States Trustee for the District of
Delaware (the “U.S. Trustee”) appointed the Committee.  See Docket No. 121.
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Basis for Relief
15.
Section 1121(d)(1) of the Bankruptcy Code permits a court to extend a debtor’s
exclusivity “for cause,” subject to certain limitations not relevant here.  Specifically, section
1121(d) of the Bankruptcy Code provides that “on request of a party in interest made within the
respective periods . . . of this section and after notice and a hearing, the court may for cause reduce
or increase the 120-day period or the 180-day period referred to in this section.”  11 U.S.C. §
1121(d).  Although the term “cause” is not defined by the Bankruptcy Code, such term should be
viewed flexibly in this context “in order to allow the debtor to reach an agreement.”  H.R. Rep.
No. 95, 95th Cong., 1st Sess. 232 (1997); see also In re Public Serv. Co. of New Hampshire, 88
B.R. 521, 533-34 (Bankr. D.N.H. 1988) (“legislative intent . . . [is] to promote maximum
flexibility”) (quoting In re Lake in the Woods, 10 B.R. 338, 340, 345 (E.D. Mich. 1981)).  Simply
put, a debtor should be given a reasonable opportunity to negotiate an acceptable plan with
creditors and to prepare adequate financial and nonfinancial information concerning the
ramifications of any proposed plan for disclosure to creditors.  See In re Texaco Inc., 76 B.R. 322,
327 (Bankr. S.D.N.Y. 1987).
16.
Courts within the Third Circuit and in other jurisdictions have held that the decision
to extend the Exclusivity Periods is left to the sound discretion of a bankruptcy court and should
be based on the totality of circumstances in each case.  See, e.g., First Am. Bank of N.Y. v. Sw.
Gloves & Safety Equip., Inc., 64 B.R. 963, 965 (D. Del. 1986); In re Dow Corning Corp., 208 B.R.
661, 664 (Bankr. E.D. Mich. 1997); In re Express One Int’l, Inc., 194 B.R. 98, 100 (Bankr. E.D.
Tex. 1996); In re McLean Indus., Inc., 87 B.R. 830, 834 (Bankr. S.D.N.Y. 1987).  In particular,
courts examine a number of factors to determine whether a debtor has had an adequate opportunity
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to develop, negotiate and propose a chapter 11 plan and thus whether there is “cause” for extension
of the Exclusivity Periods.  These factors include the following:
a) the size and complexity of the case;
b) the existence of good-faith progress towards a plan;
c) the necessity of sufficient time to negotiate a plan and prepare adequate
information to allow a creditor to determine whether to accept such plan;
d) whether the debtor is paying its debts as they become due;
e) whether the debtor has demonstrated reasonable prospects for filing a viable
plan;
f)
whether the debtor has made progress negotiating with creditors;
g) the length of time a case had been pending;
h) whether the debtor is seeking an extension to pressure creditors; and
i)
whether or not unresolved contingencies exist.
See In re Cent. Jersey Airport Servs., LLC, 282 B.R. 176, 184 (Bankr. D.N.J. 2002); McLean
Indus., 87 B.R. at 834; see also Dow Corning, 208 B.R. at 664-65 (identifying the above factors
and noting that courts generally rely on the same factors to determine whether exclusivity should
be extended); In re Friedman’s Inc., 336 B.R. 884, 888 (Bankr. D. Ga. 2005) (same).
17.
Not all of these factors are relevant to every case, and courts use only the relevant
subset of the above factors to determine whether cause exists to grant an exclusivity extension in
a particular chapter 11 case.  See, e.g., Express One, 194 B.R. at 100 (identifying four of the factors
as relevant in determining whether “cause” exists to extend exclusivity); In re United Press Int’l,
Inc., 60 B.R. 265, 269 (Bankr. D.D.C. 1986) (finding that the debtor showed “cause” to extend
exclusivity based upon three of the factors); In re Pine Run Trust, Inc., 67 B.R. 432, 435 (Bankr.
E.D. Pa. 1986) (relying on two of the factors in holding that cause existed to extend exclusivity).
For example, both Congress and courts have recognized that the size and complexity of a debtor’s
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case alone may constitute cause for extension of a debtor’s exclusive periods to file a plan and
solicit acceptances of such a plan.  H.R. No. 95-595, at 231-232, 406 (1978), reprinted in 1978
U.S.C.C.A.N. 5787, 6191 (“[I]f an unusually large company were to seek reorganization under
chapter 11, the court would probably need to extend the time in order to allow the debtor to reach
an agreement.”); see also Texaco, 76 B.R. at 326 (“The large size of the debtor and the consequent
difficulty in formulating a plan [] for a huge debtor with a complex financial structure are important
factors which generally constitute cause for extending the exclusivity periods.”).
18.
As set forth below, the Debtors’ chapter 11 cases satisfy the relevant factors and,
thus, sufficient “cause” exists to extend the Exclusivity Periods as provided herein.  There is ample
precedent in this district and others for an initial extension of exclusivity as the Debtors seek here.
See, e.g., In re Express, Inc., Case No. 24-10831 (KBO) (Bankr. D. Del. Aug. 7, 2024) (granting
an initial extension of the exclusive periods by approximately 90 days); In re Mist Holdings, Inc.,
No. 24-10245 (JTD) (Bankr. D. Del. Jun. 10, 2024) (same); In re MVK FarmCo LLC,
No. 23˗11721 (LSS) (Bankr. D. Del. Feb. 26, 2024) (same); In re Yellow Corp., No. 23-11069
(CTG) (Bankr. D. Del. Nov. 8, 2023) (same); In re PGX Holdings, Inc., No. 23-40718 (CTG)
(Bankr. D. Del. Sept. 25, 2023) (same).
I.
The Debtors’ Chapter 11 Cases Are Large and Complex
19.
These chapter 11 cases involve 28 affiliated-Debtor entities with approximately 950
full-time employees throughout the United States.  The Debtors continue to operate their global
company focused exclusively on supporting breathing through every stage of life and Vyaire’s
products are available in more than 100 countries.  As of the Petition Date, the company operated
two business segments: ventilation and respiratory diagnostics, and each segment offered
customers certain products, services and related consumables.  Additionally, the company held a
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differentiated portfolio of valuable intellectual property related to its product offerings consisting
of, among other things, over 700 U.S. patents.  Moreover, the Debtors had approximately $533.6
million in total funded debt obligations as of the Petition Date.
20.
Furthermore, the Debtors have a wide variety of parties in interest, from various
vendors and contractual counterparties to local, state and federal agencies—many of whom have
been active in these chapter 11 cases.  The Debtors also have a myriad of reporting obligations
with respect to local, state and federal taxing and regulatory agencies that the Debtors have
continued to comply with, to the extent required by the Bankruptcy Code.
21.
Accordingly, the size and complexity of these chapter 11 cases weigh in favor of
extending the Exclusivity Periods.
II.
The Debtors Have Made Good-Faith Progress Towards Exiting Chapter 11
22.
During their short time in chapter 11, the Debtors have made significant progress
in negotiating with their stakeholders and administering these chapter 11 cases.  The Debtors have
already satisfied several key milestones in these chapter 11 cases, including: (i) obtaining approval
of the Bidding Procedures Order and negotiating and obtaining final approval for debtor-in-
possession financing facility and use of cash collateral; (ii) actively engaging in a successful,
comprehensive marketing process in accordance with the Bidding Procedures Order; (iii) signing
and obtaining Court approval for the sale of substantially all of the Debtors’ Ventilation Assets to
a third-party strategic bidder for cash consideration of $37 million and the assumption of certain
liabilities; (iv) signing and obtaining Court approval for the sale of substantially all of the Debtors’
Respiratory Diagnostics Assets to a third-party strategic bidder for cash consideration in the
amount of $53.5 million and the assumption of certain liabilities; and (v) actively engaging with
stakeholders in an effort to build consensus surrounding the treatment of certain executory
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contracts and unexpired leases.  The Debtors will seek to obtain approval of the Disclosure
Statement and launch a process to solicit votes on the Plan, while simultaneously working to close
the Sale Transactions.
23.
Further, the Debtors have engaged in good faith with the Committee.  Since the
Committee’s formation, the Debtors have had extensive negotiations and shared information
related to the marketing and sale process.  The Debtors, at the Committee’s request, are facilitating
extensive and ongoing diligence and discovery and have thus far shared hundreds of documents
with the Committee.  The Debtors will continue to engage with the Committee as these chapter 11
cases progress.
24.
Accordingly, the Debtors’ substantial progress in administering these chapter 11
cases and good faith to resolve outstanding issues with the Committee and other parties-in-interest
weigh in favor of extending the Exclusivity Periods.
III.
The Debtors are Paying Their Bills as They Come Due
25.
Since the Petition Date, the Debtors have generally paid their postpetition debts in
the ordinary course of business or as otherwise provided by Court order.
IV.
These Cases Are Fewer Than Four Months Old
26.
The Debtors’ request for an extension of the Exclusivity Periods is the Debtors’
first such request and comes less than four months after the Petition Date.  As discussed above,
during this short time, the Debtors have accomplished a great deal and worked diligently toward a
timely resolution of these chapter 11 cases.
V.
An Extension of the Exclusivity Periods Will Not Pressure Creditors
27.
The Debtors are not seeking an extension of the Exclusivity Periods to pressure or
prejudice any of their stakeholders.  The Debtors have been diligently moving these chapter 11
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cases forward and the Court has already confirmed a sale of certain of the Debtors’ Ventilation
Assets and substantially all the Debtors’ Respiratory Diagnostics Assets.  Thus, the Debtors’
request for an extension to the Exclusivity Periods is not requested for the impermissible purpose
of pressuring creditors to agree to a plan.  Accordingly, the relief requested herein is without
prejudice to the Debtors’ creditors and will benefit the Debtors’ estates, their creditors and all other
key parties in interest.
28.
An objective analysis of the relevant factors demonstrates that the Debtors are
doing everything that they should be doing as chapter 11 debtors to reach a successful conclusion
to these chapter 11 cases.  Accordingly, sufficient cause exists to extend the Exclusivity Periods
as provided herein.
Notice
29.
The Debtors will provide notice of this motion to: (a) the United States Trustee for
the District of Delaware; (b) counsel to the Committee; (c) counsel to the 1L Ad Hoc Group; (d)
the agent of the DIP Facility and counsel thereto; (e) the agent of the First Lien Credit Agreement
and counsel thereto; (f) the Second Lien Credit Agreement Agent and counsel thereto; (g) the agent
of the First Lien Notes and counsel thereto; (h) any party that has requested notice pursuant to
Bankruptcy Rule 2002.  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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WHEREFORE, the Debtors request entry of the Proposed Order, substantially in the form
attached hereto as Exhibit A, (a) granting the relief requested herein and (b) granting such other
relief as the Court deems appropriate under the circumstances.
Dated: September 11, 2024
Wilmington, Delaware
/s/ Patrick J. Reilley
COLE SCHOTZ P.C.
KIRKLAND & ELLIS LLP
Patrick J. Reilley, Esq. (No. 4451)
KIRKLAND & ELLIS INTERNATIONAL LLP
500 Delaware Avenue, Suite 1410
Joshua A. Sussberg, P.C. (admitted pro hac vice)
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. (admitted pro hac vice)
Warren A. Usatine, Esq (admitted pro hac vice)
Spencer A. Winters, P.C. (admitted pro hac vice)
Court Plaza North, 25 Main Street
Yusuf U. Salloum (admitted pro hac vice)
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
Co-Counsel to the Debtors
Co-Counsel to the Debtors
and Debtors in Possession
and Debtors in Possession
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