Crossing Borders: U.S. Public Company Successfully Implements UK Restructuring Plan in the U.S. Through Chapter 15 Recognition

December 4, 2025

As we highlighted earlier this year in The Case for Good Forum Shopping:  Insights from Mega Newco, we expect the use of cross-border forums to remain a significant feature of the global restructuring landscape.  Private companies have previously amended governing law to access the English courts, but the use of an English restructuring plan by Fossil Group, Inc., a Texas-based entity, marks the first instance that U.S. governed debt issued by a public U.S. company has been restructured outside the U.S.  The restructuring, now fully enforceable in the U.S. via Chapter 15 of the U.S. Bankruptcy Code, also contained features that otherwise would not be permissible under Chapter 11.

Download PDF