To cram-down a chapter 11 plan on non-accepting classes, at least one impaired class must accept the plan, not counting the votes of insiders. In what is likely to be a controversial opinion, the Ninth Circuit Court of Appeals upheld a decision by the Bankruptcy Appellate Panel that the purchaser of a bankruptcy claim was not an “insider” for plan-confirmation purposes, even though the purchaser acquired the claim from the debtor-LLC’s sole member, an insider, under questionable circumstances.