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Email On December 19, 2019, the United States Court of Appeals for the Second Circuit (the “Second Circuit”) affirmed a ruling of the United States District Court for the Southern District of New York (the “District Court”) dismissing constructive fraudulent conveyance claims brought by representatives of certain unsecured creditors of Chapter 11 debtor Tribune Company (“Tribune”) against Tribune’s former shareholders on the ground that the fraudulent conveyance claims were barred by Bankruptcy Code section 546(e)’s safe harbor provision. https://www.cadwalader.com/resources/clients-friends-memos/no-youre-a-customer--recent-second-circuit-decision-circumscribes-merit-and-preempts-state-law-impairment-of-safe-harbor-protections-in-the-wake-of-a-failed-lbo