Earlier this summer, the Delaware Bankruptcy Court issued an opinion in the New Century Holdings bankruptcy addressing the definition and purpose of the "Divestiture Rule."  See Carr v. New Century TRS Holdings, Inc. (In re New Century TRS Holdings, Inc.), Adv. No. 09-52251(KJC)(Bankr. D. Del.

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On August 15, 2011, Evergreen Solar ("Evergreen"), filed chapter 11 petitions for Bankruptcy in the United States Bankruptcy Court for the District of Delaware.  According to the Declaration of Evergreen's CEO, Michael El-Hillow (the "Declaration" or "Decl."), filed in support of its bankruptcy petitions, Evergreen incorporated in Delaware in 1994 and manufactures "multi-cystalline silicon wafers."  The company uses its silicon wafers in the production of photovoltaic solar cells, which in turn are installed in solar panels under the Evergreen trade name.  Decl. at 3.

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Last year, the Liquidating Trustee (the "Trustee") in the Midway Games bankruptcy began filing avoidance actions against creditors of the bankruptcy estate. Midway Games ("Midway" or the "Debtor") filed petitions for bankruptcy in the United States Bankruptcy Court for the District of Delaware on February 12, 2009. For those not familiar with this bankruptcy proceeding, Midway developed and distributed video games throughout the North America, Europe and Asia.

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On October 12, 2010, Consolidated Horticulture Group, LLC and Hines Nursery LLC (the "Debtors"), filed petitions for bankruptcy in the United States Bankruptcy Court for the District of Delaware. According to the Declaration filed by Debtors' President and CEO, Stephen Thigpen (the "Declaration"), Debtors are one of the largest commercial nurseries in North America, selling shrubs and container-grown plants to commercial and retail customers. Decl.

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Introduction

American Safety Razor Company ("ASR"), one of the largest manufacturers of shaving razors and blades, filed for bankruptcy protection in Delaware on July 28, 2010. According to the Declaration of ASR's Chief Financial Officer, Andrew Bolt (the "Bolt Declaration"), the company's net sales for 2009 totaled $330 million, down from the $351 million in sales achieved in 2008. See Bolt Declaration, pgh. 11.

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Introduction

Section 548 of the United States Bankruptcy Code allows for the avoidance of transfers that are either intentionally or constructively fraudulent. Section 548 provides, in relevant part, as follows:

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