First, the not-so-great news in figures:

When a bankruptcy debtor rejects a lease, a landlord is entitled to a rejection damages claim. Under Section 502(b)(6) of the Bankruptcy Code, a landlord’s claim is capped at “the rent reserved by such lease, without acceleration, for the greater of one year, or 15%, not to exceed three years, of the remaining term of such lease.”

Courts have taken two different approaches in interpreting what constitutes the “15%” in the statute: (A) the remaining rent due under the lease; or (B) the remaining time under the lease.

The “Rent Approach”

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures:

First, the not-so-great news in figures: