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On January 30, 2023, the U.S. Court of Appeals for the Third Circuit (the “Court”) issued an opinion in In re LTL Management, LLC, No. 22-2003, 2023 WL 1098189, at *1 (3d Cir. Jan. 30, 2023) (“LTL Management”), in which Judge Thomas L. Ambro reversed the prior ruling of the U.S. Bankruptcy Court for the District of New Jersey and dismissed Johnson & Johnson, Inc. (“J&J”) affiliate LTL’s chapter 11 petition. Specifically, the Court ruled that because the chapter 11 debtor (LTL) “was not in financial distress, it cannot show its petition served a valid bankruptcy purpose and was filed in good faith under Code § 1112(b).”