Kemsley, 44 Misc. 3d 773 (N.Y. Sup. 2014) (chapter 15 recognition was not necessary to enforce, at the request of an individual debtor, a discharge order in a UK bankruptcy proceeding, even though a U.S. bankruptcy court previously denied the UK bankruptcy trustee's petition for chapter 15 recognition of the bankruptcy, because chapter 15's plain language applies only to a "foreign representative" such as a trustee). The Third Circuit's decision in Vertiv adds another chapter to the debate. The refreshed guidance it provides illustrates that, notwithstanding chapter 15, there may be other comity avenues for foreign debtors or tribunals to utilize to centralize restructuring-related claims and issues in a foreign restructuring proceeding. At a minimum, the updated comity guidance provided by the Third Circuit is also instructive for analyzing whether to extend comity to judgments in non-insolvency proceedings taking place abroad. Read the full Business Restructuring Review.