On December 14, 2020, the Bankruptcy Court for the Southern District of Texas in Chuck E. Cheese’s chapter 11 proceeding reaffirmed that section 365(d)(3) of the Bankruptcy Code generally requires commercial tenants in bankruptcy to continue to perform all of their lease obligations, including the payment of rent, subject to the bankruptcy court’s limited authority to modify the timing of performance for obligations that arise within the first sixty (60) days of the bankruptcy proceeding.