Law360, New York (September 17, 2014, 10:01 AM EDT) -- The United States District Court for the District of Delaware recently entered a memorandum opinion concerning the constitutional sufficiency of the publication of the bar date notice in the New Century bankruptcy as it applies to unknown creditors.[1] The district court vacated the bankruptcy court's Aug. 30, 2013, order (the "constructive notice order"), which had approved the constitutional sufficiency of notice to unknown creditors by publication in The Wall Street Journal and the Orange County Register. In vacating the constructive notice order, the district court concluded that the publication notice "likely was not reasonably calculated to apprise appellants of the bar date" and remanded the matter to the bankruptcy court for further proceedings.[2]...