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Case: Lehman Brothers International (Europe) (in administration) [2018] EWHC 1980 (Ch), Hildyard J (27 July 2018)

The High Court decision in Burnden Holdings clarifies the law on retrospective attacks on the declaration of dividends.

SUMMARY

On May 20, 2019, the Supreme Court settled a circuit split concerning whether a debtor’s rejection of a trademark license under § 365 of the Bankruptcy Code “deprives the licensee of its rights to use the trademark.” In a decision written by Justice Kagan, the Supreme Court held that while a debtor-licensor’s rejection of a trademark license results in a pre-petition breach, it does not constitute a rescission of the contract, and thus the licensee may retain the rights granted to it under the license.

The Supreme Court’s recent decision in Mission Product Holdings, Inc., v. Tempnology, LLC  clarifies that a debtor-licensor’s rejection of a trademark license under § 365(a)  of the Bankruptcy Code is treated as a breach, and not as a rescission, of that license under § 365(g).  The Court held that if a licensee’s right to use the trademark would survive a breach outside of bankruptcy, that same right survives a rejection in bankruptcy.

In 2018, approximately 40 companies in the oil and gas industry filed bankruptcy in the United States, including companies engaged in exploration and production, oilfield services, and midstream services.

SUMMARY

The Court of Appeal of England and Wales (“CA”) made a significant ruling on two matters affecting the powers and duties of directors of English companies.

On January 17, 2019, the United States Court of Appeals for the Fifth Circuit (the “FifthCircuit”) issued a decision in In re Ultra Petroleum Corp. that could have significant implications for creditors seeking payment of contractual make-whole amounts and post-petition interest from chapter 11 debtors.[1]