In December 2008, the Tribune Company — the nation’s second-largest newspaper publisher and a large multimedia corporation — filed for bankruptcy. The filing made headlines as the largest bankruptcy in the history of the American media industry. Approximately four years later, the legal wrangling in this matter continues, with one of the main sticking points being the competition between two proposed restructuring plans.

In a recent decision out of the Tribune bankruptcy proceeding, Hon. Kevin J. Carey of the U.S. Bankruptcy Court for the District of Delaware, evaluated the contours of 11 U.S.C. § 1129(a)(10) of the federal Bankruptcy Code, in the context of considering the conformability of competing Chapter 11 plans of reorganization for the jointly administered debtors. See In re Tribune Co., et al., Case No. 08-13141 (KJC), 2011 Bankr. LEXIS 4128 (Bankr. D. Del. Oct. 31, 2011) ( Tribune ).