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Chapter 11 Plan

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How Far Can a Plan Injunction Reach? Delaware Weighs In on Gatekeeping

By Carl D. Neff on November 15, 2025

On August 21, 2025, Judge Craig T. Goldblatt of the United States Bankruptcy Court for the District of Delaware issued a significant ruling in In re AIO US, Inc. (the Avon Products bankruptcy) that rejected a “gatekeeping” provision in a proposed Chapter 11 plan. The court held that neither the Bankruptcy Code nor the Barton…

Posted in Bankruptcy Cases, Opinions

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