Netflix, Inc. v. Relativity Media, LLC (In re Relativity Fashion, LLC)

Case Type:
Case Status:
16-3282-bk (2nd Circuit, Aug 22,2017) Not Published
(1)Bankruptcy court had post-confirmation jurisdiction to adjudicate dispute over interpretation of contract assumed by debtor during bankruptcy-if Netflix had been permitted to stream films before release, it would have effectively destroyed revenue streams anticipated by plan and had great impact on reorganization.(2)Arbitration was not appropriate-court's finding that bankruptcy interests in protecting reorganization plan outweighed arbitration interests was not clearly erroneous.(3)Bankruptcy court's interpretation of contract as precluding pre-release streaming was not clearly erroneous.
Procedural context:
SUMMARY ORDER; NO PRECEDENTIAL EFFECT. Appeal from judgment of the district court, which affirmed an order of the bankruptcy court.
Debtor Relativity Media, LLC, brought a motion in bankruptcy court to enforce its Chapter 11 plan of reorganization against Netflix to preclude Netflix from distributing two of the debtor's films through its video-streaming service before those films were released in theaters, and Netflix moved to compel arbitration.
Reena Raggi and Raymond J. Lohler, Jr., Circuit Judges, and Joan M. Azrack, District Judge for E.D.N.Y. sitting by designation

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