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Volume IX, Issue 39

Oct. 1, 2026

 

In re: Financial Oversight & Management Board for Puerto Rico, Case Nos. 25-1745, 25-1748, 25-1749, 25-1750 & 25-1751 (1st Cir. 2026). 
Section 510(b) of the Bankruptcy Code requires subordination when a damages claim has a sufficient causal nexus to the purchase or sale of a debtor’s or its affiliate’s security, including when post-purchase conduct allegedly impaired rights that induced the purchase. 

 

Bultemeyer v. CenturyLink, Inc., Case No. 24-6413 (9th Cir. 2026). 
A defendant does not willfully violate the Fair Credit Reporting Act under Safeco when its statutory interpretation has a foundation in the text, no federal appellate court has addressed the issue, and no sufficiently specific authoritative agency guidance warned against that interpretation. 

 

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Manny Farach

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