On December 1, 2025, the U.S. District Court for the Southern District of New York issued a decision in In re GOL Linhas Aéreas Inteligentes S.A., 675 B.R. 125 (S.D.N.Y. 2025), reversing a bankruptcy court’s confirmation of third-party releases that relied on an opt-out mechanism. Judge Denise Cote held that a creditor’s silence—a failure