Law360, New York (November 29, 2012, 12:34 PM EST) -- The threat of a "cramdown" in a Chapter 11 proceeding under the Bankruptcy Code is one of a real estate lender's worst nightmares. As a practical matter, however, this has been quite difficult for a debtor to achieve. A February 2012 decision by the Bankruptcy Appellate Panel for the Ninth Circuit appeared to make it much simpler for a debtor to engineer a successful "cramdown," by permitting the separate classification of two otherwise similarly situated creditors, where one of them is the beneficiary of a third-party guaranty. But at least two subsequently published decisions in which debtors tried to invoke the panel's reasoning suggest that other courts may be reluctant to follow suit....