In Sandridge Energy, the bankruptcy court expressed skepticism regarding the Sabine holding; however, in announcing a settled resolution of the dispute, the debtors' counsel explained that the amount at issue did not justify the expected cost of litigation. 22 In Quicksilver Resources, the issue arose in connection with a sale of the debtors' assets under section 363 of the Bankruptcy Code, as the debtors' success on a motion to reject certain midstream contracts governed by Texas law was a condition precedent to closing the sale. 23 The initial Sabine decision was issued several days after oral argument on the Quicksilver rejection motion, and the parties settled shortly thereafter. The debtors withdrew the rejection motion, and the purchaser agreed to enter into replacement midstream agreements with a corresponding reduction of the agreed purchase price by $2.5 million.