Vitro: Defining 'Manifestly Contrary' To US Policy

Law360, New York (May 8, 2012, 5:31 PM EDT) -- Chapter 15 of the Bankruptcy Code provides a procedure to obtain recognition of a foreign bankruptcy, insolvency or debt adjustment proceeding (a "foreign proceeding") in the United States. Upon recognition of a foreign proceeding, creditors and other parties in interest in the United States are generally enjoined or stayed from taking action against the foreign debtor that would be in contravention of the foreign proceeding.

Assuming all the requirements for obtaining recognition, which have been described as "formulaic," are satisfied, a United States court will grant...
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