In late 2014, in a decision that may greatly increase the leverage of holdout bondholders in non-judicial debt restructurings, hedge fund managers holding unsecured debt were denied the injunction they sought of a proposed restructuring of a company’s debt.  This article summarizes the factual background of the case and the court’s reasoning.  For a discussion of other options available to aggrieved debt holders, see “Coercive Exchanges: How Hedge Fund Noteholders Can Salvage Value Under Duress,” Hedge Fund Law Report, Vol. 6, No. 23 (Jun. 6, 2013).  For a look at holdout litigation involving sovereign debt, see “Bondholders, Including Hedge Funds, Win Latest Round in Battle with Republic of Argentina over Payments on Defaulted Sovereign Bonds,” Hedge Fund Law Report, Vol. 6, No. 36 (Sep. 19, 2013).  For another interpretation of the Trust Indenture Act relevant to hedge fund managers that invest in structured products, see “Second Circuit Panel Stays Mum on Whether Trust Indenture Act Applies in All Securitization Deals,” Hedge Fund Law Report, Vol. 7, No. 24 (Jun. 19, 2014).