Law360, New York (December 23, 2014, 4:04 PM EST) -- German bond market investors were burned badly by the twin bankruptcies of Pfleiderer AG (wood materials producer with over EUR 1 billion in funded debt) and Q-Cells SE (photovoltaic cell manufacturer with nearly EUR 1 billion in funded debt) in Spring 2012. Bondholders in those cases saw the Frankfurt Appellate Court (Oberlandesgericht Frankfurt, hereinafter "OLG Frankfurt") save defeat from the jaws of victory in a much-criticized decision that sided with dissident bondholders and effectively ended both companies' out-of-court restructuring efforts. In a recent decision, however, the German Supreme Court (Bundesgerichtshof, hereinafter "BGH") openly departed from the OLG Frankfurt's ruling and, in going so, reopened a restructuring path under the 2009 German Bond Act (the "New Bond Act") that should put would be hold-out bondholders of German companies on notice....