With Robert Bressler, Geoffrey Goodman
In Clear Channel (Clear Channel Outdoor, Inc. v. Knupfer, 391 B.R. 25 (B.A.P. 9th Cir. 2008)), the Bankruptcy Appellate Panel for the Ninth Circuit (BAP) issued a potentially sweeping decision on the ability of a debtor to sell its assets free and clear of out-of-the-money liens under § 363(f) of the Bankruptcy Code.