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Dorsey’s Corporate Trust Services practice group advises trustees, fiduciaries, and other service providers involved in a wide array of financing and related transactions. Dorsey is a leading law firm in the corporate trust sector, and clients rely on us for day-to-day operational advice, structuring and completion of transactions, defense of litigated claims, and representation and assistance in default and workout scenarios. Dorsey's Corporate Trust Services team is centered in various U.S. offices and the firm's London office. Dorsey also has deep experience in the acquisition of corporate trust businesses.

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德汇美国破产法问答(系列之六)Dorsey U.S. Bankruptcy Law Q&A Series Six

December 14, 2020

德汇外国供应商破产法团队 Dorsey & Whitney Bankruptcy Team for Foreign Suppliers We hope that you found the five previous Q&A series regarding what to do when a U.S. customer files for Chapter 11 bankruptcy protection helpful. You can check them out here: [One, Two, Three, Four, and Five]. This Series Six will address questions relating to the plan process, including the disclosure and solicitation process, what happens if a plan is or is not confirmed, and how that impacts your right to a distribution. 希望我们之前五篇关于“如何应对美国客户申请第11章破产保护”的美国破产法问答系列文章(点击查看)对您有所裨益。本文为该系列第六篇文章,将解答与第11章计划程序相关的问题,包括披露和意见征集程序、第11章计划通过与否的不同后果,以及该等后果将如何影响您获得破产财产分配的权利。 1. Question: What is a Chapter 11 plan and are there different types? 问题1:什么是第11章计划?是否存在不同类型? A Chapter 11 plan, once approved by the bankruptcy court, governs the debtor’s exit from bankruptcy and the treatment of claims against and interests in the debtor’s estate. A Chapter 11 plan may either provide for reorganization or liquidation of the debtor. Whereas reorganization will involve the debtor itself continuing operations, liquidation will often involve the sale of substantially all of the debtor’s assets to a new company. A debtor may accomplish a number of other transactions through a plan, including a merger, the creation of a liquidating trust, modification of liens, or issuance of new debt or equity. 一经破产法院批准,第11章破产计划将决定债务人如何从破产程序中退出,以及各项权利主张和利益在债务人财产中的分配。第11章计划可以规定债务人的重组或清算。重组会涉及债务人本身的持续经营,而清算往往涉及将债务人的绝大部分资产出售给另一家新公司。债务人可以通过第11章计划完成一系列其他交易,包括合并、创设清算信托、修改留置权或发行新债或新股。 2. Question: How can I learn more about a proposed plan and its effects? 问题2:我如何评估一项拟议计划及其影响? A debtor is required to file and serve upon all creditors a disclosure statement containing adequate information regarding the proposed plan to enable a creditor to make an informed judgment regarding whether or not to vote in favor of the plan. The disclosure statement will include information regarding, among other things, the treatment of different types of claims and estimated recoveries, what led to the bankruptcy filing, and what has taken place during the bankruptcy case. Both the proposed plan and disclosure statement tend to be lengthy, detailed documents and it would be worthwhile to retain U.S. bankruptcy counsel to review them on your behalf, to determine how your rights will be affected and to guide you through the confirmation process. 债务人必须提交一份披露声明,并将该声明送达所有债权人。该披露声明应包含关于拟议计划的所有相关信息,以使债权人能够就是否通过该计划作出合理且明智的判断。此外,披露声明将包括不同类型的权利主张的处理方式和预计赔偿金额、导致破产申请的原因以及在破产案件中所发生的事件等内容。拟议计划和披露声明基本都是详细而冗长的文件,因此,我们建议您聘请美国破产法律师为您审查该等计划和声明,以判断您的权利可能受到何种影响,并指导您完成计划确认过程。 3. Question: What is the proposal, solicitation, and confirmation process like and what role do suppliers play?  问题3:提案、意见征集和确认流程是什么样的?供应商在这些过程中扮演什么角色? Chapter 11 debtors are given the exclusive right to file a plan during the early months of the case, and are often the only party to do so even after the exclusive period comes to an end. The plan proponent will first request approval of a disclosure statement and solicitation and notice procedures with respect to the proposed plan. Once approved, the plan proponent solicits acceptance of the plan in accordance with the approved procedures. The solicitation materials will include copies of the plan and disclosure statement, a ballot, directions and deadlines for submitting the ballot and objecting to confirmation, and notice of the confirmation hearing. When solicitation is complete, a confirmation hearing will be held before the bankruptcy court. 第11章债务人享有在破产案件开始后的几个月内提交计划的专属权利,并且,即使在专属期限届满后,债务人通常也是唯一提交计划的当事方。计划发起人将首先就与拟议计划有关的披露声明、意见征集和通知程序寻求批准。一旦获得批准,计划发起人将按照经批准的程序,就该计划征集意见。意见征集材料将包括计划和披露声明的副本、选票、提交选票和拒绝确认该计划的相关指引和截止日期,以及确认听证会的通知。当征集过程完成后,破产法院将举行确认听证会。 To the extent a supplier’s pre-bankruptcy claim against a debtor does not qualify as a reclamation claim or for “critical vendor” treatment (see Series Two), its claim will typically be classified as general unsecured. General unsecured claims are placed near the back of the line for distribution, behind several other typical classes of claims, e.g. secured and administrative. As a result, suppliers’ pre-bankruptcy, non-reclamation, non-critical vendor claims are often impaired, meaning they will not receive a full recovery. 如果供应商对债务人的破产前债权不构成货物召回权,或不能享有“关键供应商”的待遇(见系列二),其债权通常被归类为一般无担保债权。一般无担保债权处于债权偿付的最后顺位,排在其他几种典型债权之后,例如,有担保债权和行政费用债权。因此,供应商破产前的、非货物召回权的以及非关键供应商的债权通常会受到影响,即无法得到全额偿付。 Holders of impaired claims are entitled to vote on a plan unless they are not entitled to any distribution, in which case they are typically deemed to reject the plan. A plan may be confirmed over the objection of a dissenting impaired class if the plan satisfies certain requirements, including that at least one impaired class has accepted the plan and the plan is fair, equitable, and does not unfairly discriminate as to classes of claims and interests.  在通常情况下,权利受损的债权人都有权对计划进行表决,但,在债权人不能基于其债权得到偿付时,其无权对该计划进行表决,并且该债权人将被视为拒绝确认该计划。如果计划满足特定要求,这些要求包括至少有一个无法得到全额偿付的债权人接受了该计划、该计划是公平和公正的,并且该计划未对各种索赔请求和利益造成不公平的歧视,那么即使无法得到全额偿付的债权人反对该计划,该计划仍可得到确认。 4. Question: What happens if the bankruptcy court confirms a proposed plan? 问题4:如果破产法院确认了一项拟议的第11章计划会有什么影响? If the bankruptcy court confirms a proposed plan, the debtor consummates the transactions contemplated by the plan on an effective date. This will likely include distributions to creditors, such as administrative expense creditors that provided goods and services to the debtor during the bankruptcy case. To the extent such suppliers are not paid in the ordinary course during the bankruptcy case, they must be paid in full on the effective date in order for the plan to be confirmed. General unsecured creditors may receive a distribution of cash or securities on the effective date, but often plans provide for the creation of a liquidating trust out of which distributions to general unsecured creditors are made depending on the extent to which the trust successfully liquidates assets and prosecutes claims on behalf of the post-confirmation estate. 如果破产法院确认了一个拟议的第11章计划,则债务人应在该计划规定的一个生效日完成该计划规定的交易。这可能包括分配给债权人的偿付款项,例如在破产案件中向债务人提供货物和服务的行政管理费用债权人。如果行政管理费用债权人在破产案件中未能通过正常流程获得偿付的,他们在生效日也必须得到全额偿付,这是破产重组计划的确认要求之一。一般无担保债权人可在计划生效日起得到现金或证券方式的偿付。但通常第11章计划会规定设立清算信托,根据信托成功清算的资产和代表第11章破产计划确认后的债务人财产提起索赔的程度,向一般无担保债权人分配偿付款项。 Confirmation of the plan will result in the discharge of all pre-bankruptcy liabilities of the debtor, meaning creditors cannot pursue their pre-bankruptcy claims against the debtor even if the confirmed plan does not pay such claims in full. Indeed, the plan substitutes a debtor’s pre-bankruptcy obligations to its creditors with those obligations set forth in the plan. 随着计划的确认,债务人破产前的所有债务将会被解除。这意味着即使有些债权人无法得到全额偿付,他们也不能就破产前的债权向债务人进行索赔。事实上,第11章计划用其中规定的义务替代了债务人破产前的义务。  5. Question: What happens if the bankruptcy court denies confirmation of a proposed plan? 问题5:如果破产法院拒绝确认拟议计划,会发生什么? If a bankruptcy court denies confirmation of a proposed plan, the debtor may amend its plan and seek confirmation of the amended plan, or the debtor or another party in interest may propose an alternative plan. If the estate lacks liquidity to continue reorganization proceedings, the bankruptcy court may convert the case to a liquidation under Chapter 7 of the Bankruptcy Code or dismiss it entirely. If the case is converted to Chapter 7, the debtor’s business operations will cease and a trustee will be appointed to marshal and liquidate the debtor’s assets for the benefit of creditors. In that event, the costs of administering the Chapter 7 case will take first priority, meaning general unsecured creditors are one step farther back in the line for distributions. 如果破产法院拒绝确认一项拟议计划,债务人可以修改其计划并寻求对修改计划的确认,或者债务人或其他利益相关方可以提出替代计划。如果破产财产由于缺乏流动性无法继续进行重组程序,破产法院可根据《破产法》第7章将该案件转为清算案件,或将案件完全驳回。如果该案件被转为第7章的清算案件,债务人的业务将停止,并且被指定的受托人将会为债权人的利益,管理和清算债务人的资产。在破产案件转为清算案件的情况下,管理第7章案件的行政费用将得到优先偿付,这也意味着一般无担保债权人的债权偿付顺序将进一步置后。 6. Question: What is the likelihood that a Chapter 11 case will be successful? 问题6:第11章案件成功的可能性有多大? Chapter 11 is open to businesses of all sizes and to individuals. As a result, a considerable proportion of Chapter 11 cases filed in the United States are unsuccessful and result in dismissal or conversion to liquidation under Chapter 7. However, in our experience, larger cases (meaning those where the debtor has over $10 million in assets or liabilities) are dramatically more likely to succeed, particularly because they are more likely to have the resources needed to complete a successful reorganization under Chapter 11. Often, larger cases will involve the sale of substantially all of the debtor’s assets to a new company, the proceeds of which are used to pay creditors.  第11章适用于各种规模的企业和个人。因此,在美国提交的第11章案件中,有相当一部分是不成功的,并且被驳回,或根据第7章转为清算案件。然而,根据我们的经验,标的额较大的案件(指债务人资产或负债超过1000万美元的案件)成功的可能性要大得多,主要是因为它们具备根据第11章进行重组所需的资源。通常,标的额较大的案件将涉及将债务人的大部分资产出售给一家新公司,而所获收益将用于偿付债权人。 While a successful Chapter 11 case may result in some creditors receiving less than they are due, the ultimate result is usually that a business is able to continue operating which benefits the nation’s economy as a whole. As such, reorganization in the U.S. is appropriately viewed as an essential element of our capitalist system. 虽然一个成功的破产法第11章案例可能会导致一些债权人收到的偿付款项少于其到期应收款项,但一个企业最终能够继续经营,这对整个国家的经济都有好处。因此,重组被视为美国资本主义制度的一个基本要素。 *** We do hope that you enjoyed these series and now have a fuller understanding of the Chapter 11 process, at least as it may impact the rights of foreign suppliers of bankrupt U.S. companies. From the outset of the bankruptcy case, a creditor’s rights are directly impacted – whether through imposition of the automatic stay which prohibits further collection efforts or through the imposition of a 20-day deadline to file reclamation claims measured from the filing date. As such, as soon as you learn of a customer’s bankruptcy filing, you should contact your trusted U.S. bankruptcy counsel to guide you through the process, ensure you do not miss any key dates or deadlines, and obtain the greatest recovery possible. 我们希望您通过美国破产法问答系列文章,对第11章的程序有更全面的认识,至少了解该程序对破产美国公司的外国供应商权利的影响。自破产案件开始,债权人的权利就受到直接影响——无论是通过“自动中止令”禁止进一步债务催收,还是通过对提出货物召回权主张设置自破产申请之日起算20日的截止期限。因此,一旦您得知客户的破产申请,您应立即联系您信任的美国破产法律师帮助您,确保您不会错过任何关键日期或截止日期,并获得最大程度的偿付。 If you have more questions, please do not hesitate to reach out to the Dorsey & Whitney Bankruptcy Team for Foreign Suppliers. 如有您有任何问题,请随时联系美国德汇律师事务所外国供应商破产法团队。 ------------------------------------------- Dorsey & Whitney is an international law firm with more than 100 years of history and 21 offices in the U.S., Canada, Europe, and Asia, including Beijing, Shanghai, and Hong Kong. Dorsey serves business organizations across a wide range of industries and is recognized by Chambers USA and U.S. News Best Law Firms. 德汇律师事务所是一家拥有超过百年历史的国际律师事务所,在美国、加拿大、欧洲和亚洲(包括北京、上海和香港)设有 21 家办公室。德汇为各行各业的企业提供全方位法律服务,并被《钱伯斯美国》评选为“领先律师事务所”以及被U.S. News评选为“最佳律师事务所”。 Dorsey & Whitney Bankruptcy Team for Foreign Suppliers 外国供应商破产法团队  

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(德汇美国破产法问答系列之五)Dorsey U.S. Bankruptcy Law Q&A Series Five

December 11, 2020

德汇外国供应商破产法团队 Dorsey & Whitney Bankruptcy Team for Foreign Suppliers We hope that you found the four previous Q&A series regarding what to do when a U.S. customer files for Chapter 11 bankruptcy protection helpful. You can check them out here: [One, Two, Three, and Four]. This Series Five will address questions relating to the role of official unsecured creditors committees in bankruptcy and considerations of whether to join such a committee. 希望我们的美国破产法问答系列一、系列二、系列三和系列四 “如何应对美国客户申请第11章破产保护”的文章对您有所裨益。本文为该系列第五篇文章,将针对官方无担保债权人委员会在破产案中的作用,以及在决定是否加入该委员会时的考量进行讲解。 1. Question: What is the official unsecured creditors committee and what role does it play in Chapter 11 bankruptcy cases? 问题一:什么是官方无担保债权人委员会?它在第11章破产案件中有何作用? The official unsecured creditors committee (the “UCC”) is a statutorily authorized committee of unsecured creditors whose role is to advocate, as a fiduciary, on behalf of all unsecured creditors in a Chapter 11 case. The UCC is entitled to obtain valuable information in the case and advances the interests of all unsecured creditors to ensure such interests are represented in the bankruptcy process.  官方无担保债权人委员会(“债委会”)是法律明文授权的无担保债权人委员会,在第11章破产案中作为受托人代表所有无担保债权人发声。债委会有权获得案件重要信息并且推动所有无担保债权人的利益,确保该等利益在破产程序中得以体现。 The UCC is usually comprised of three to seven of a debtor’s largest unsecured creditors that are willing to serve. The UCC takes an active role in steering the Chapter 11 case and may, with court approval, investigate the debtor, its financial affairs, and its business operations. The UCC will usually participate in the formulation of a plan of reorganization and is afforded consultation rights in connection with any sale of the debtor’s assets. 债委会通常由债务人的最大无担保债权人中愿意担任债委会职务的三到七位债权人组成。债委会在第11章破产案件中发挥积极的引导作用,且在法院批准情况下,可对债务人及其财务和商业运营情况开展调查。债委会通常会参与制订破产重组计划,并被赋予与债务人资产出售有关的咨询权。 The UCC is entitled to its own advisors, including counsel, and the related professional fees and other costs are borne by the bankruptcy estate and not the individual members of the UCC. While the costs of the UCC’s advisors are paid by the bankruptcy estate, the UCC is not otherwise entitled to any compensation for its work in the case. Individual members may wish to retain their own counsel to assist them in their role on the UCC, and the cost for such individual counsel is borne by the individual committee member. 债委会有权聘请自己的顾问,包括法律顾问,相关专业费用和其他开支由破产资产而非债委会个人成员承担。虽然债委会的顾问费用由破产资产支付,但债委会无权另行就其在破产案件中的工作获得任何补偿。债委会个人成员可能会希望聘请自己的法律顾问协助其在债委会的工作,该笔费用则由债委会的个人成员承担。 2. Question: Should I join the UCC? 问题二:我是否应该加入债委会? That depends. Being a member of the UCC means that you will have an active and important role in the bankruptcy case and serve the interests of unsecured creditors. The UCC typically negotiates recoveries under a plan of reorganization for unsecured creditors or, in less common instances, proposes its own plan of reorganization.  视情况而定。担任债委会成员意味着您在破产案件中将扮演积极重要的角色,为无担保债权人的利益服务。债委会通常为无担保债权人在破产重组计划下的追偿款进行谈判,或,在少数情况下会提出自己的破产重组计划。 Serving on the UCC requires some time commitment. The UCC and its advisors typically convene about once a week during periods of significant activity, and less often other times, until a plan is confirmed. As noted above, individual UCC members often retain their own counsel to assist and advise in connection with UCC obligations (e.g. participate in UCC meetings), in addition to representing the member’s personal interests. Regardless of whether a member of the UCC acts on its own or through counsel, each member of the UCC owes a fiduciary duty to all unsecured creditors and must act for the benefit of all unsecured creditors. This means that members of the UCC cannot act solely in their own interests. Being a member of the UCC will also often involve receiving and reviewing confidential information about the debtor that must be kept confidential. 在债委会任职需要投入一定的时间。债委会及其顾问通常在破产重组计划确认前的重要时刻,大约每周召开一次会议,其他时间会议召开频率通常较低。如上所述,除了代表债委会成员的个人利益外,债委会个人成员还经常聘请自己的法律顾问就债委会的义务(例如,出席债委会会议)提供协助和法律建议。无论债委会成员亲自还是通过法律顾问行事,每位债委会成员均对所有无担保债权人负有受托责任,并且必须为所有无担保债权人的利益服务。这意味着债委会成员不能仅为了其自身利益服务。作为债委会的成员,还经常会收到并审阅有关债务人的保密信息,必须严格保密。 3. Question: What role does the U.S. Trustee play with respect to the committee and in a Chapter 11 case generally?  问题三:美国受托人办公室通常在债委会和第11章破产案件中扮演何种角色? The U.S. Trustee, which is part of the U.S. Department of Justice, oversees all bankruptcy cases filed throughout the U.S. At the outset of large and mid-size Chapter 11 cases, the U.S. Trustee will reach out to the debtors’ largest unsecured creditors and ask whether they would be willing to serve on the UCC. If and once the U.S. Trustee has appointed the UCC, it plays no role on the UCC itself. Rather, the UCC determines what actions to take in the bankruptcy case, with the advice of counsel. 美国受托人办公室隶属美国司法部的下属机构,负责监督美国各地提交的所有破产案件。在大中型第11章破产案件伊始,美国受托人办公室将联络债务人的最大无担保债权人,并且询问其是否愿意在债委会任职。如果且一旦,美国受托人办公室任命成立债委会,美国受托人办公室本身不会对债委会起到任何作用。相反,债委会在法律顾问的建议下,对破产案中采取的行动作出决定。 The U.S. Trustee is often referred to as the “bankruptcy watchdog” and acts to ensure everyone plays by the rules – whether that be debtors, creditors, or other parties in interest. During the Chapter 11 case, the U.S. Trustee will actively monitor the case, with particular attention to the retention and payment of the debtor’s professionals, compensation of debtor’s management, and proposed plans of reorganization and whether they provide for releases for non-debtors.   美国受托人办公室经常被称为“破产案的守门人”,负责确保每个人依规则行事——无论是债务人、债权人还是其他利益方。第11章破产案期间,美国受托人办公室将积极监督案件进展,特别关注债务人专业顾问的聘用和付款、债务人管理层的薪资、拟议的破产重组计划及其是否为非债务人提供某种豁免。 4. Question: Can multiple creditors work together and retain the same counsel? 问题四:多个债权人是否可以共同聘用同一位法律顾问? Yes, so long as there is sufficient disclosure to and informed consent by all creditors retaining the same counsel. Indeed, large Chapter 11 cases often feature a variety of ad hoc committees of similarly situated creditors and interest holders, in addition to the formally appointed UCC, which act in the interests of their respective groups. This can be an effective way for creditors to increase their leverage while keeping costs down. However, informal groups of creditors do not have the same powers and advantages as the UCC and, importantly, will not be entitled to have their costs and expenses paid by the bankruptcy estate. 可以,只要所有聘请同一位法律顾问的债权人获得充分披露,并且一致同意。事实上,除正式任命的债委会外,大型第11章破产案件通常还设有各种由类似情况的债权人和利益持有人组成的特别委员会,为其各自团体利益履职。对债权人而言,这样既可以有效增加谈判筹码,同时又可以降低成本。不过,债权人的非正式团体不具有与债委会同等的权力和优势,更重要的是,其开支和费用无权由破产资产支付。 *** Please keep an eye out for Series Six which will address issues relating to the plan process, including the disclosure and solicitation process and what happens if a plan is or is not confirmed. 请您密切关注本系列的第六篇文章,该文章将解答有关破产计划程序,包括披露和招揽程序,以及破产计划是否通过所对应的不同后果。 ------------------------------------------- Dorsey & Whitney is an international law firm with more than 100 years of history and 21 offices in the U.S., Canada, Europe, and Asia, including Beijing, Shanghai, and Hong Kong. Dorsey serves business organizations across a wide range of industries and is recognized by Chambers USA and U.S. News Best Law Firms. 德汇律师事务所是一家拥有超过百年历史的国际律师事务所,在美国、加拿大、欧洲和亚洲(包括北京、上海和香港)设有 21 家办公室。德汇为各行各业的企业提供全方位法律服务,并被《钱伯斯美国》评选为“领先律师事务所”以及被U.S. News评选为“最佳律师事务所”。 Dorsey & Whitney Bankruptcy Team for Foreign Suppliers 外国供应商破产法团队  

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Dorsey Partner Melissa Raphan Elected a Fellow of the College of Labor & Employment Lawyers

International law firm Dorsey & Whitney LLP is pleased to announce that Partner Melissa Raphan has been elected a Fellow of the College of Labor & Employment Lawyers (CLEL) as part of its 2026 class. “Melissa’s election to this prestigious fellowship comes as no surprise to those of us who have had the privilege of working with her,” says Peter Nelson, Dorsey’s Managing Partner.  “She is an exceptional employment lawyer, a trusted advisor, and a leader whose impact extends far beyond her matters. Clients rely on her deep knowledge, strategic counsel, and ability to navigate complex workplace disputes and sensitive employment matters with both confidence and compassion. She has helped shape our firm, strengthen our profession, and opened doors for countless others through her commitment to mentorship and diversity. We are incredibly proud of her accomplishments and delighted to see her receive this recognition.” CLEL is a nonprofit professional association that honors the nation’s leading attorneys in the field of labor and employment law. Originally established to recognize excellence in the profession, CLEL has evolved into a respected intellectual and practical resource for the legal community and its many audiences. Its mission centers on recognizing individuals who have made significant contributions to the field, fostering the exchange of knowledge and delivering value to academia, government, the judiciary, and the broader public. Election as a fellow represents the highest level of peer acknowledgment, reflecting sustained achievement, integrity, and a commitment to advancing the profession. Melissa’s career reflects CLEL’s mission. She has been recognized both regionally and nationally for her advocacy, leadership, and achievements both inside and outside of the courtroom. Her employment litigation experience spans class actions, collective actions, and high-stakes individual disputes in state and federal courts, as well as arbitration forums including the American Arbitration Association and the Financial Industry Regulatory Authority (FINRA). She is also a trusted advisor on a full range of workplace issues, from hiring and performance management to sensitive terminations and organizational change. She brings decades of experience representing clients across the financial services, healthcare, food and agriculture, and energy sectors. Melissa will be formally inducted during CLEL’s installation ceremony held in conjunction with the American Bar Association’s Labor & Employment Law Conference in Washington, D.C., on November 7.

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37 Dorsey Attorneys Named 2026 Top Lawyers by Minnesota Monthly

Minnesota Monthly has recognized 37 Dorsey attorneys across 27 practice areas as 2026 Top Lawyers in Minnesota. Honorees are selected through a peer nomination process and a curated survey of practicing attorneys in Minnesota, who identify leading lawyers across a range of practice areas. Administrative / Regulatory Law Jennifer Coates Antitrust Law Michael Lindsay Banking & Financial Service Law Peter Nelson Copyright Law  Jeffrey Cadwell Corporate Law  Robert Hensley Robert Rosenbaum Criminal Defense: White-Collar  Beth Forsythe Edward Magarian RJ Zayed Health Care Law  Claire Topp Immigration Law  J. Mike Sevilla Insurance Law  Daniel Brown Intellectual Property and Patent Law  Stuart Hemphill International Trade Law  Jonathan Van Horn Labor and Employment Law  Edward Magarian Ryan Mick Melissa Raphan Land Use & Zoning  Jay Lindgren Marcus Mollison Litigation – Antitrust  Michael Lindsay F. Matthew Ralph Jaime Stilson Litigation – Commercial  Michael Lindsay Litigation – Construction  Eric Ruzicka Litigation – Intellectual Property  Peter Lancaster RJ Zayed Litigation – Labor Employment Benefits  Ryan Mick Melissa Raphan Litigation – Trusts and Estates  William J. Berens Theresa Bevilacqua Bridget Logstrom Koci Mass Tort Litigation / Class Actions  James K. Langdon Mergers & Acquisitions Law  Keith Ahlgren Rachel Benedict Brian Burke Morgan Helme John Jorgenson Brian Moore Robert Rosenbaum Jonathan Van Horn Bri Whiting Municipal Law Jay Lindgren Nonprofit/Charities Law Claire Topp Securities / Capital Markets Law Cam Hoang Robert Rosenbaum Securities Regulation Theresa Bevilacqua James K. Langdon Tax Law William J. Berens Trusts and Estates Jennifer Ede Bridget Logstrom Koci Sonny Miller Kiley Petty Henry

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Real Estate Attorney Alexis Olsen Joins Dorsey in Phoenix

Attorney Alexis Olsen has joined Dorsey & Whitney LLP as Of Counsel in the Real Estate group in Phoenix, the law firm announced today. Alexis focuses her practice on large-scale residential, mixed-use, and multi-asset development projects as well as multi-state commercial leasing transactions. She guides clients through sophisticated acquisitions, dispositions, leasing, entity structuring, investment strategies, and due diligence matters. She has structured co-investment arrangements that drive capital deployment into housing subdivisions nationwide and has represented both landlords and tenants in commercial leasing transactions involving office, retail, industrial, and specialty-use properties, including cannabis dispensaries. Alexis received her J.D. from Sandra Day O’Connor College of Law and her B.A. from the University of Arizona. Alexis comes to Dorsey from Squire Patton Boggs. “Alexis strengthens Dorsey’s real estate capabilities at a time when Phoenix remains one of the fastest-growing and most dynamic real estate markets in the country,” said Scott Jenkins, Dorsey’s Phoenix office head. “Her addition further enhances our deep bench of 12 real estate attorneys in Phoenix and reflects our continued investment in serving clients throughout Arizona and supporting their real estate transactions and objectives across the country. We are thrilled to welcome Alexis to Dorsey.” “Joining a firm with such a deep bench of experienced attorneys in the Phoenix office, especially in the Real Estate group, presents an exciting opportunity not just for my own professional growth, but for the clients we service,” said Alexis Olsen. “I look forward to building on this strong foundation, growing our national practice, and delivering top-tier service to our clients.”

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Proposed CMS Rule Ramps Up Potential Medicare Fraud Administrative Remedies

On July 6, 2026, the Centers for Medicare & Medicaid Services (“CMS”) proposed a rule that would expand its administrative remedies to combat potential fraud. The proposed rule is the latest in a round of administrative actions that signal CMS’s intent to aggressively pursue allegations of Medicare and Medicaid fraud and heighten the risk of fraud enforcement against even well-intentioned Medicare and Medicaid providers and suppliers. The proposed rule includes several changes to regulations that govern Medicare billing privileges. Providers and suppliers should be aware that these changes dramatically expand the flexibility afforded to CMS in enrollment and revocation actions, potentially leading to harsh consequences for ministerial and administrative errors. If finalized, moreover, the proposed rule could have material implications for providers and suppliers facing threatened revocation, including heightened risk of overpayment liability and increased hurdles to challenging revocations and denials of enrollment. Added Flexibility to Existing Revocation Grounds CMS has proposed to remove a number of factors that the regulations list as relevant to a determination of whether a provider has engaged in “abuse of billing privileges.” While acknowledging that the inclusion of these factors in the regulations was permissive (requiring consideration only where “as appropriate or applicable”), CMS stated that it must be afforded “the maximum flexibility to address all possible . . . scenarios without the rigid constraints of our existing factors.” CMS provided little guidance as to the outer bounds of what conduct could constitute an “abuse of privileges” that merits revocation of Medicare billing privileges. Instead, CMS noted that a “pattern of practice” of abuse of billing privileges might be established “by a simple finding that several of a provider’s claims do not meet Medicare requirements.” Similarly, CMS has proposed to expand the regulatory provision that permits revocation of enrollment if a provider certifies as “true” false or misleading information in Medicare enrollment application or renewal forms to include any scenario in which a provider submits “false or misleading information on or associated with any CMS Medicare enrollment-related form,” including materials submitted to Medicare contractors. CMS stated that it interprets this expanded rule to include anything related to Medicare enrollment, and not only those submissions that are “intended to gain or maintain Medicare enrollment.” If finalized, the proposed rule would add significant flexibility to CMS’s ability to pursue revocation of a provider’s enrollment. While CMS has assured providers that it would “invoke [the revised regulations]. . . only when legitimately warranted under the facts and circumstances and not as a matter of course,” such expanded flexibility threatens unpredictability in the event of even administrative or ministerial errors in submissions and claims. These changes would, moreover, make it more difficult for providers to challenge a revocation action. Expanded Revocation Grounds In addition to adding flexibility to existing grounds for revocation, CMS’s proposed rule adds to and expands CMS’s already broad authority to revoke provider and supplier enrollment. Such proposed changes include adding the following grounds for revocation: Denial of Enrollment Application. Where CMS could previously revoke a provider’s other enrollments if one enrollment is revoked, CMS would also be able to revoke a provider’s existing enrollments if an application for enrollment submitted by the provider is denied. High-Risk Enrollments. CMS would be able to revoke enrollment if it determines the provider or supplier (including owning/managing employees or organizations) poses a high risk of fraud, waste, or abuse due to “. . . an affiliation under [42 C.F.R.] § 424.519” or “the provider’s or supplier’s location within a limited geographic area that has an excessive number of providers and suppliers.” Certain Misdemeanor Convictions. CMS would be able to revoke enrollment if a provider or supplier—or its owners, managing employees, managing organizations, officers, or directors—are convicted of a “misdemeanor related to sexual assault or financial misconduct within the past 10 years that CMS deems detrimental to the best interests of the Medicare program and its beneficiaries.” Ownership Changes (HHA, Hospice, DMEPOS). CMS would have broad authority to revoke enrollment of home health agencies, hospices, and DMEPOS suppliers who do not comply with the regulations governing provider changes of ownership. These proposed, expanded grounds for revocation are notably broad, and CMS provides only limited guidance as to what conduct might result in revocation under these grounds. As with the proposed expansion of existing grounds for revocation, the open-ended nature of these proposed grounds for revocation may make it more difficult for providers and suppliers to challenge revocation actions. Expanded Grounds to Deny Medicare Enrollment As with revocations, CMS proposes to expand the grounds under which a provider’s application to enroll in Medicare can be denied. These expanded and additional grounds include many of the grounds added for revocations, but also include: Medicare Debt or Payment Suspension. CMS proposes expanding the ground to deny enrollment based on Medicare debt or payment suspension to include a provider or supplier’s “managing employee, managing organization, or individual or entity with any other form of business or financial relationship with the provider or supplier[.]” Significantly, this expansive definition (called an “associated party” under the proposed regulation) currently contains no material limitations, meaning almost any person or entity with whom an applicant does business could create denial liability. Sharing Locations with Denied/Revoked Providers or Suppliers. CMS would have authority to deny applications where a “provider’s or supplier’s practice location is in the same suite or office as another provider or supplier whose Medicare enrollment has been revoked or denied.” Hospices with Distant Medical Directors or Administrators. CMS would have discretion to deny hospice applications if the hospice’s medical director or administrator serves “multiple other hospices” or practices/is located “at such a distance (for example, in a different state) from the enrolling hospice that the medical director cannot realistically perform all medical director functions,” with a similar provision for administrators. In addition, CMS proposes applications denied for “other program termination or suspension,” may be applied to the provider or supplier in its own name or NPI or that of its owners, managing employees, or managing organization regardless of whether any appeals are pending. Retroactive Revocation CMS proposed to restructure and expand the regulatory grounds for retroactive revocation of billing privileges. Currently, Medicare regulations provide that revocations are, by default, prospective in nature: effective 30 days after CMS or the CMS contractor mails notice to the provider. Under certain circumstances, the regulations provide for revocations to be retroactive, such as when a provider is convicted of a felony, the date a professional license is suspended, revoked, or surrendered, or when a provider submits a false certification in their enrollment application. CMS has proposed to reframe the rule so as to default to retroactive revocation of billing privileges. CMS expressed concern that providers may collect payment from Medicare while remaining so non-compliant with enrollment requirements as to merit revocation. To address this concern, CMS proposed that all revocations be retroactive to the date of determined non-compliance.[1] As a result, providers suspected of misconduct or non-compliance are likely to face claims of retroactive overpayments in addition to the immediate concern no longer receiving Medicare payments while their enrollment is revoked. Reapplication Bar CMS’s proposed rule expands the grounds from which a provider may be prohibited from seeking reapplication as a Medicare provider. Under current regulations, CMS may prohibit prospective providers from enrolling in Medicare for up to 10 years if its enrollment application is denied because the applicant submitted false or misleading information in its application. Under the proposed rule, CMS will have the discretion to prohibit a provider from enrolling in Medicare if their enrollment application is denied for any reason. Conclusion As a part of the federal government’s increasingly aggressive push to combat real or perceived healthcare fraud, the proposed rule both broadens CMS’s authority to revoke and deny Medicare enrollment and raises the stakes for revocation and denial. What the proposed rule does not share is how CMS plans to exercise this expanded discretion: as a result, the proposed rule, if enacted, increases the unpredictability and potential ramifications of even technical noncompliance with CMS rules. As a result, Medicare providers should keep a close eye on potential revisions to these rules and their potential implementation and consider proactively evaluating their compliance under CMS standards. [1] In the proposed rule, CMS identifies, with respect to each ground for revocation, what it will consider to be the effective date of revocation.

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Litigation Privilege Does Not Automatically Protect Communications with Funders: The Commercial Court Clarifies the Limits of Privilege in the Context of Litigation Funding

In Uber London Ltd & Ors v Garry White & Ors; Mishcon de Reya LLP [2026] EWHC 1610 (Comm), the Commercial Court held that documents created to help a funder decide whether to invest in a claim will not ordinarily attract litigation privilege. This means that information a firm gathers while acting for a funder can later fall within the control of the claimants it goes on to represent in the same matter. Background The Claimants (a claim group of over 10,000 individual London black cab drivers and the assignee of two former minicab operators) alleged that the Defendants (three companies in the Uber group) obtained and retained their private hire operator's licence through an unlawful means conspiracy alleged to involve fraud. Because the claims were issued outside the ordinary six-year limitation period, the Claimants relied on section 32 of the Limitation Act 1980, contending they could not, with reasonable diligence, have discovered the fraud before June 2018. A preliminary issue trial was listed to determine the question of whether the Claimants discovered, or could have discovered with reasonable diligence, the alleged fraud and/or deliberate concealment only after June 2018. The Claimants were represented by Mishcon de Reya ("MdR"). However, before MdR’s engagement with the individual drivers had begun, in late 2017 it was engaged by the litigation funder Harbour to investigate the merits and value of the potential claim. During that stage, MdR corresponded extensively with Harbour and with the Licensed Taxi Drivers' Association ("LTDA"), a black cab drivers' trade association. MdR was not formally engaged by the Claimants until October 2018 onwards. Once the proceedings had started, the Defendants sought disclosure of communications exchanged between MdR and Harbour before the engagement of MdR by the Claimants (the "Harbour Communications"). This included correspondence between MdR and Harbour, communications with the LTDA, and documents held on MdR's file opened in Harbour's name in connection with the potential claim. The Claimants resisted disclosure on four grounds: (i) that the documents were not relevant; (ii) on the grounds of litigation privilege; (iii) that the documents were outside their control; and (iv) that disclosure occurring so close to trial would be disproportionate. Judgment (i) Were the Harbour Communications relevant to the preliminary issue? The Court held that the Harbour Communications were likely to contain relevant material, on two bases. First, where the Claimants or the LTDA had communicated directly with MdR, that material could shed light on individual Claimants' actual knowledge of the alleged facts. Secondly, what MdR and Harbour had discovered during their investigation could inform the question of what a Claimant could reasonably have discovered at the time (even though the Defendants accepted that MdR's knowledge could not simply be imputed to the Claimants). (ii) Were the Harbour Communications protected by litigation privilege? As set out in the classic cases of Three Rivers (No. 6) [2005] 1 AC 610 and WH Holding Ltd v E20 Stadium LLP [2018] EWCA Civ 2652, communications between parties or their solicitors and third parties for the purpose of obtaining information or advice in connection with existing or contemplated litigation are privileged when the following conditions are satisfied: Litigation must be in progress or in reasonable contemplation. The communications must have been made for the sole or dominant purpose of conducting litigation. The litigation must be adversarial, not investigative or inquisitorial. The Court rejected the Claimant’s claim to be able to withhold the Harbour Communications on the basis of litigation privilege. The Court confirmed that litigation privilege protects only communications created for the dominant purpose of conducting litigation. The Court found that Harbour had instructed MdR so that Harbour could decide whether to fund the proceedings. As such, the dominant purpose of the communications was in relation to funding, not the conduct of litigation. This was distinguished from the situation where an individual litigant who takes its own funding decision. In that situation, the decision whether to fund and the decision whether to litigate are one and the same, made by the person who will actually be the claimant, and so it forms a part of that person's conduct of their own litigation. In contrast, a third-party funder's commercial decision whether to fund someone else's claim is not necessarily part of conducting that litigation. The fact that litigation privilege can, in principle, be claimed by a non-party funder (as recognised in the case of Al Sadeq v Dechert [2024] EWCA 28) did not assist Harbour, since there was no evidence it intended to play any role in the litigation itself beyond funding it. Communications between Harbour and MdR did remain capable of attracting another kind of privilege: legal advice privilege, because of the solicitor-client relationship between Harbour and MdR. But communications with third parties such as the LTDA were not automatically protected in the same way. (iii) Were the Harbour Communications within the Claimants' control? The Court also rejected the argument that the Harbour Communications sat outside the Claimants' control because they belonged to Harbour and not the Claimants. The Court’s reasoning was that once the individual Claimant drivers became MdR's clients, MdR also owed them a duty to disclose material information. That included information that MdR had originally acquired while acting for Harbour. As held in the case of Hilton v Barker Booth & Eastwood (a firm) [2005] 1 WLR 567, a solicitor owing duties to two clients cannot simply prefer one over the other, and it was unrealistic to suppose MdR would investigate the same claims for Harbour, then represent the Claimants, while disregarding everything it had already learned. The obvious commercial expectation was that this earlier work would be used to advance the Claimants' case. MdR sought to rely on a confidentiality clause in a 2024 retainer agreement between it and RGL Management Ltd (a claims management company acting on behalf of the Claimants) to argue that it was relieved of any duty to disclose information obtained while acting for other clients. The provision stated that MdR may "have acted for persons in the same or similar sector as yours and by agreeing to the terms of this letter you agree that will have no duty to disclose to you any confidential information that we have obtained, or might in the future obtain, from acting for such persons or which is derived from any other source". The Court rejected this on several grounds. Claimants who had already become MdR's clients had an existing right to information in the Harbour Communications where it was relevant to their claims before the 2024 retainer agreement. If they were to surrender that right, it would have required their informed consent (also required under the SRA Code of Conduct). The Court found no evidence that such informed consent had been given. The terms had simply been made available to the Claimants through a portal, with no indication that Claimants understood they were giving up existing rights to relevant information. The Court found that even if the terms had been contractually binding, that would not have amounted to informed consent. In addition, the wording of the clause was not sufficiently clear to show that the Claimants had agreed to waive access to this information. (iv) Was disclosure reasonable, proportionate, and necessary at this stage? The Claimants argued that it was neither reasonable nor proportionate for disclosure to be given at such a late stage (approximately two weeks before the start of the preliminary issue trial) and that it was not necessary for the just disposal of the proceedings. The Court rejected this, but it drew a distinction between two categories of documents within the Harbour Communications: Documents bearing on the actual knowledge of the individual drivers, including communications with the LTDA, were not privileged, likely straightforward to review, and directly relevant to the preliminary issue. Their disclosure was ordered as reasonable, proportionate, and necessary. Documents reflecting only MdR's or Harbour's own assessment of the merits were of more marginal, indirect relevance and largely likely to fall under legal advice privilege. A review to isolate the smaller pool of non-privileged material in this category would be time-consuming for limited benefit, so this was excluded from the order. Key Points to Note The judgment is an important reminder of several practical points: However closely a funder is involved in evaluating a claim's merits, litigation privilege will only apply to communications where the sole or dominant purpose of the communication is the conduct of litigation, not the funder's own decision on whether to finance it. Unless that communication separately attracts legal advice privilege, it may need to be disclosed. The same considerations apply to other communications. For example, in RBS Rights Litigation [2017] 1 WLR 3539 the argument that an After the Event (ATE) policy was subject to litigation privilege was rejected on a similar basis. Whilst in this case, there was no dispute as to whether litigation was in contemplation, it is important to note that litigation privilege will not automatically apply to the investigative stages of a claim, i.e. before litigation is in contemplation. Even where litigation is reasonably contemplated, the dominant purpose test must still be satisfied. Material created primarily for fact-finding, risk assessment, or other investigative purposes will not attract litigation privilege unless those activities are actually undertaken for the dominant purpose of conducting the litigation. (See The Director of the Serious Fraud Office v Eurasian Natural Resources Corporation Ltd [2017] EWHC 1017 (QB)). When engaging a law firm, clients should ensure that they understand whether the firm has previously obtained information about their claim while acting for another party (for example, a funder or another interested party) and how that information will be handled. Any restrictions on the firm’s ability to share relevant information with the client should be explained clearly at the outset, including what information may be withheld and why. If this decision raises questions about your own funding arrangements, disclosure strategy, or privilege position, please get in touch with our Commercial Litigation team.

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Alaska HB 126: What Changes for Alaska Native Corporations, Proxy Filings, and Annual Reports

Alaska House Bill 126 (HB 126), sponsored by Representative Neal Foster and passed by the 34th Alaska Legislature, is now law. The bill changes which Alaska Native Corporations (ANCs) must file proxy and annual report materials with the State of Alaska, and makes it easier to reinstate certain dissolved Village Corporations. For many smaller Village Corporations, the practical result is less public disclosure. For shareholders, advisors, and the public, it means some financial information that used to be available through the State will no longer be readily obtained. This eUpdate explains what HB 126 does in plain terms, walks through the practical trade-offs, and answers common questions. 1. What HB 126 Changes The old rule Under prior law (Alaska Statutes Sec. 45.55.139), an Alaska Native Corporation had to file its annual report, proxies, and proxy statements with the Alaska Division of Banking and Securities (the Division) if it had more than $1 million in assets and 500 or more shareholders on its current rolls. A filing ANC was also required to follow the Division’s proxy rules (3 AAC 08.305 through .365), which require specific disclosures such as top 5 executive compensation, and related-party transactions. Because these filings are treated as public records, they gave non-shareholders, including the public and the press, visibility into ANC financial information that is not filed with the SEC. The new rule HB 126 changes how the 500-shareholder test is measured. Now, the asset test is removed, and the shareholder count is based on how many shareholders the corporation originally enrolled when it was formed under the Alaska Native Claims Settlement Act (ANCSA), not how many it has today. As shares have passed down through families over the decades, some Village Corporations that started with fewer than 500 shareholders now have more than 500 recordholders. Under the old current-count test, when those corporations had crossed the threshold, they had to file. Under the new original-enrollment test, they do not. Who is affected Village Corporations that originally enrolled fewer than 500 shareholders are the main beneficiaries. They no longer have to file proxy and annual report materials with the Division or follow the Division’s proxy regulations at 3 AAC 08.305 through .365. Two groups must continue to file as before: all twelve ANCSA Regional Corporations, each of which enrolled more than 500 shareholders at creation, and all Village Corporations that originally enrolled 500 or more shareholders. As reported by the Alaska Beacon, when the bill was under consideration, the Division identified 59 corporations then filing, expected at least seven village corporations to become exempt, and was reviewing roughly 30 more. 2. Practical Analysis HB 126 reduces a real compliance burden for smaller Village Corporations, which now need not spend time and money on State filings. In coming years, the exempt Village Corporations may experience benefits associated with less public disclosure and less regulation. But at the same time, less public disclosure carries trade-offs. Benchmarking will become harder Publicly-filed proxy statements and annual reports have long served as a reference set. Shareholders, corporations, advisors, and counsel use them to compare governance practices, compensation, and financial results across similarly-situated ANCs. Since fewer of these materials will be filed publicly, there will be fewer comparable documents available, which will make benchmarking and market-checking more difficult for like-sized ANCs over time. Executive compensation transparency may be reduced The Division’s proxy rules require disclosure of the compensation of ANC’s top five most highly compensated individuals (3 AAC 08.345(b)(2)), related-party transactions above $20,000 (3 AAC 08.345(b)(3)), and audited financial statements and management’s discussion and analysis (3 AAC 08.365). When a corporation is no longer required to file these disclosures publicly, it becomes harder for shareholders and others to obtain the information, to understand how compensation is set for their corporate leadership, and how it compares across corporations of similar size and complexity. Transparency may matter more as ANCs grow Some ANCs have grown into large, complex enterprises with substantial revenue and many subsidiaries, even with fewer than 500 shareholders. For an ANC with a broad and dispersed shareholder base, public materials can be an important way for shareholders and other stakeholders to understand governance, compensation, and performance across ANCs. Reduced disclosure may carry more practical weight in those settings than for a small corporation whose shareholders are closely connected to the business. The ANCSA annual report obligation continues It is important not to overstate what HB 126 does. HB 126 changes the state filing proxy requirements. It does not remove the separate obligation under ANCSA itself. That obligation comes from ANCSA at 43 U.S.C. Sec. 1625(c), which requires a Native Corporation that would otherwise be subject to the Securities Exchange Act of 1934 to prepare and transmit to its shareholders an annual report containing substantially the information a company subject to that Act would include. Similarly, ANCs that solicit proxies for an annual meeting are still required to furnish shareholders with those proxy materials under general Alaska corporate law. However, ANCs are now no longer required to transmit proxy statements to the State. ANCs’ reporting obligations to their shareholders are unaffected by HB 126. Any corporation newly exempt from state filing still owes its shareholders a detailed annual report and a proxy statement, even though that report is no longer routed through the State and made public. Reinstatement of dissolved Village Corporations Separately, HB 126 amends AS 10.06.960(k) to remove the prior deadline (previously December 31, 2020) for reinstating an involuntarily dissolved Native Village Corporation. A dissolved Village Corporation may now apply to be reinstated under AS 10.06.633(e) at any time. Reinstatement still runs through the commissioner under AS 10.06.633(e). In general, that means the ANC must apply, cure the neglect or delinquency that led to dissolution, and pay the amounts owed, and the corporation’s name must be available or be changed to one that is. Once reinstated, the corporation and its shareholders are restored to the rights, privileges, liabilities, and obligations they would have had as if the dissolution had never occurred, and corporate and shareholder actions taken during the dissolution are treated as valid. If the previously-used corporate name is no longer available, the board alone may amend the articles to adopt a new name (without the necessity for shareholder approval). 3. Frequently Asked Questions What does HB 126 do? It changes how Alaska measures the 500-shareholder test that decides which ANCs must file proxy and annual report materials with the state. It removes the asset test, and it counts shareholders based on original enrollment rather than the current rolls. It also removes the deadline for reinstating an involuntarily dissolved Native Village Corporation. Which ANCs are affected? Village Corporations that originally enrolled fewer than 500 shareholders, because they may no longer need to file with the Division. Regional Corporations and Village Corporations that originally enrolled 500 or more shareholders must continue to file as before. Does HB 126 eliminate all reporting obligations? No. It changes the state filing requirement under AS 45.55.139, but it does not remove the separate ANCSA obligation (43 U.S.C. Sec. 1625(c)) to provide shareholders with an annual report, and general corporate law still calls for a proxy statement when the ANC solicits proxies. Corporations that remain subject to state filing requirements must also continue to comply with the Division's rules. We think we are now exempt. What should our ANC board and management consider? Confirm your ANC’s original enrollment number and whether your corporation falls below the new threshold. Watch for communications from the State on this topic as they proceed with their research. If your ANC is now exempt, decide how your corporation will meet its continuing ANCSA obligation to shareholders, review proxy and annual meeting materials and timelines, and consider what to communicate to shareholders about any change in how they will receive information. It is worth documenting the basis for any exemption. What should ANC shareholders watch for? Shareholders should watch for how and when they will continue to receive annual report and proxy statement information directly from their ANC, since some material that used to be available through the State’s online website will no longer be publicly filed. If something is unclear, shareholders can ask their ANC how it intends to meet its ANCSA reporting obligations. How Dorsey Can Help HB 126 lightens the State filing load for smaller Village Corporations, but it also raises practical questions: confirming who is exempt, meeting continuing ANCSA obligations to shareholders, keeping proxy and annual meeting processes on track, and maintaining benchmarking when public materials become less available. These are exactly the kinds of judgment calls that benefit from early planning. Dorsey’s attorneys work closely with Alaska Native Corporations and related stakeholders. If you have questions about HB 126, ANC governance, proxy filings, annual reports, disclosure obligations, or shareholder communications, please contact your Dorsey attorney, including the authors of this eUpdate.

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The Long-Awaited Public Infrastructure Financing Solution for Development in Arizona

Every developer who has taken raw Arizona ground to a finished project knows the largest upfront cost other than the land price is almost always the cost to install the public infrastructure. Water, sewer, stormwater, streets, dry utilities, and the fiber backbone all have to be in the ground before a single lot closes or a building opens. That capital is deployed early and generates no return for years. For decades the standard workaround has been the Community Facilities District (CFD). That tool has grown materially harder to use, for reasons cited below, and House Bill 2999, signed in June 2026 and now codified as Chapter 40 of Title 48, is Arizona's response. Some Background I have spent a good part of my career on the other side of this problem. In the 1990s and early 2000s I served as general counsel of SunCor Development Company, one of Arizona's most active master-planned community developers, where we used Community Facilities Districts to finance hundreds of millions of dollars of major infrastructure across Arizona in cities such as Goodyear, Phoenix, Tempe, Litchfield Park, and Prescott Valley. For its time the CFD was an effective structure, and a great deal of what is now on the ground in those communities was financed with this tool. Unfortunately, CFDs have over time become considerably harder to use. Successive legislative amendments have layered on tax-rate ceilings, homebuyer disclosure obligations, and added procedural steps. Another drag on the use of CFDs is that formation of them runs through the municipality, where approval can turn as much on local politics as on the merits of a project. Developers now routinely are asked to absorb delay and uncertainty that a project's economics cannot support, which is a large part of why Arizona has fallen behind Colorado, Texas, and Utah in getting infrastructure financed. A better tool was needed, and Chapter 40 is it. How a SAID Improves on a CFD A State Affordability Infrastructure District (SAID) keeps what worked about the CFD: tax-exempt, property-secured, non-recourse infrastructure financing — while shedding much of what made the CFD cumbersome. Its principal advantages over a traditional CFD: Administrative formation. A SAID is formed by the Arizona Finance Authority against fixed statutory criteria, through a yes-or-no compliance review on a sixty-day clock, rather than through the discretionary approval of a city council or a board of supervisors. Insulation from municipal politics. Because formation is a state-level compliance determination, a meritorious project is far less exposed to local political headwinds than it is under the CFD process. Landowner control of the board. A SAID is governed by a board of the landowners — appointed at formation, then elected on an acreage basis. In a typical municipal CFD, the city council sits as the district board; here, the developer controls governance. Advance funding of impact fees. A SAID can use bond proceeds to advance-pay municipal development impact fees, unlike CFDs, removing one of the largest upfront cash burdens in a project. A uniform, statewide process. The criteria are the same regardless of jurisdiction, replacing the municipality-by-municipality variation that has made CFD outcomes hard to predict. Flexible boundaries. A district may include noncontiguous parcels in the same county within five miles of one another, which fits phased and multi-tract development. Capped cost and a fixed timeline. Authority fees to form a district are capped at $15,000, and a complete petition must be acted on within sixty days. The full range of bonds. A SAID may issue general obligation, special assessment, revenue, and refunding bonds, secured solely by district property and creating no obligation for any other taxpayer. What is a SAID A SAID is a special taxing district that the owners of a development form to finance public infrastructure with tax-exempt bonds: general obligation bonds, special assessment bonds, and revenue bonds. The bonds are secured only by the property inside the district and are repaid over the long term, with terms up to 30 years. They do not affect the credit of the city, the county, or the State, and they create no obligation for any taxpayer outside the district. In practical terms, a SAID lets you finance horizontal infrastructure over the life of the asset instead of writing the check at the front end. The maximum ad valorem rate securing general obligation bonds is capped by statute at $5.00 per $100 of net assessed limited property valuation, with a limited step-up to cover a debt-service shortfall. SAIDs Work for Commercial as Well as Residential Development The SAID bill drew most of its press as a housing-affordability measure, and it appears to be a strong one. It is the first Arizona district statute to let bond proceeds advance-fund municipal development impact fees, which pulls one of the largest upfront cash burdens off a homebuilder's pro forma. But the statute's eligible infrastructure categories apply with equal force to commercial, industrial, and mixed-use projects. An industrial or logistics project can finance roads, rail crossings, sidings, and grade separations. A life-sciences or technology campus can finance its water, sewer, roads, and broadband the same way a subdivision can. Read Chapter 40 as a general-purpose infrastructure finance platform, not a subdivision-only device. How Formation Works A SAID is formed administratively by the Arizona Finance Authority. The Authority reviews the petition for compliance with the statute; it is a yes-or-no review against fixed criteria, not a discretionary negotiation with a city council or a board of supervisors, and it runs on a sixty-day clock once a complete petition is filed. Formation requires the written consent of 100% of the landowners in the proposed district and an engineer's certification that public infrastructure costs will exceed $5 million. The district may include noncontiguous parcels so long as they lie in the same county and within five miles of the district's other property, which accommodates phased and multi-tract development; if any part of the district sits inside a municipality, the whole district must stay within that municipality's limits or planning area. The Authority's fees to form a district are capped at $15,000. Issuing bonds requires a district election. Governance Simplified A SAID is run by a three-member board. The initial directors are named in the petition; after that, directors are elected by the landowners on an acreage basis as ownership diversifies. Board service runs with ownership; a director must either hold fee title inside the district or be an individual designated by a fee-title owner; and corporations, partnerships, and other entities may hold that ownership, vote as owners, and designate the individual who serves. A district has no power of eminent domain and no zoning authority, and directors may not be officials or employees of the municipality in which the district sits. What a SAID Does Not Do It finances; it does not entitle. Zoning, platting, rezonings, use permits, and the specialized approvals a manufacturing or life-sciences facility may need all remain with the local jurisdiction and proceed on their own track. The financing and entitlement timelines should be coordinated with formation of the SAID, but they are separate processes. Two substantive limits are worth flagging at the planning stage. First, electric power is largely outside the tool: the statutory definition of public infrastructure does not reach power generation or transmission, and broader energy infrastructure was removed from the bill during the Senate amendments. A power-intensive user should not assume a SAID will carry its electrical load. Second, where water, sewer, or wastewater facilities fall within a regulated utility's certificated service territory, the district cannot build or own them without the utility's written consent and must convey them to the utility upon completion. Our Take For most master-planned residential work, and for a wide range of commercial and industrial development, a SAID will be the most efficient infrastructure-financing structure Arizona has offered. The right time to evaluate it is early in the acquisition and pre-development process, while the capital stack, the development agreement, and the entitlement strategy are still being set. Once the district's boundaries, general plan, and financing parameters are set, it is cumbersome at best to bring those into conformance later. Our Dorsey team has begun advising our developer clients on SAID formation on residential, commercial, and industrial projects statewide. If you would like us to assess whether a SAID fits a project you are working on, please reach out.

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State Affordability Infrastructure Districts (SAIDs) — A Financing Tool for Taiwanese Investment in Arizona Science and Technology Parks

If you have developed a facility inside one of Taiwan's science or technology parks, you are accustomed to the one-stop-shop of government planning the park and delivering the roads, water, power, and other infrastructure before your building is even constructed. In the United States, including Arizona, land development generally does not work that way. In Arizona, the cost of infrastructure such as water, sewer, stormwater, roads, power, and the digital backbone, typically falls on the private landowner and is incurred up front before operations generate revenue to offset that cost. For a company entering the Arizona market, this is often the largest and earliest capital burden of the entire project. Arizona recently created a tool that provides a more cost-effective way for landowners and developer to finance some of that infrastructure. House Bill 2999, signed into law June 2026 and codified at Chapter 40 of Title 48 of the Arizona Revised Statutes, establishes the creation of a State Affordability Infrastructure District (SAID). How a SAID Works Landowners are now able to use a SAID to finance public infrastructure such as water, sewer, stormwater, roads, parking, lighting, communications, rail sidings and signalization, and similar improvements, through tax-exempt bonds. The bonds are repaid over up to 30 years and secured solely by the property within the SAID. No city, county, or state credit is pledged, and no obligation falls on other taxpayers, and therefore no city, county, or state approval other than from the Arizona Finance Authority (AFA). In effect, a SAID lets you spread the cost of horizontal infrastructure over the life of the asset instead of funding it entirely at the outset. And tax-exempt bonds often offer a lower interest rate than taxable or other types of financing. How a SAID is Formed A SAID is formed upon the filing of a petition with the AFA. The petition must include the finance plan, general plan, estimated costs, maximum tax rate, appraisal, bond counsel certificate, consultant list, petitioner experience, legal description, title report, and other materials. While the landowner is required to provide notice to the local governing jurisdiction, local governing jurisdiction does not have the right to approve or deny. The petition is reviewed administratively by the AFA through a standards-based process. For an inbound investor without long-standing local relationships, an objective, criteria-driven process is a meaningful advantage to the overt political process associated with other financing districts in Arizona. Formation requirements. A SAID requires consent from 100% of landowners within the proposed district; public infrastructure costs must exceed $5 million (easily met at any real scale); the district property must all be in the same county and need not be contiguous provided that noncontiguous property is located within five miles of the district's other property; and the board is initially appointed by the forming owners of the SAID district, later transitioning to election as ownership diversifies. Actual bond issuance requires an election of the SAID property owners. Ownership and corporate structure. Consent rights and board seats run with title. If you hold the Arizona land through a U.S. blocker beneath your Taiwan parent, the standard model for Taiwanese/Arizona real estate and operating investment, the U.S. property-holding entity, rather than it’s corporate parent, is the landowner of record for the district. Before formation, our Dorsey team will confirm that you have the proper corporate structure and board mechanics to be compliant.  Board composition has no citizenship or residency requirement. This is a common concern for foreign investors, and the statute answers it cleanly. Under A.R.S. § 48-7004, a director must either hold fee title to real property in the district or be an individual designated or appointed by a fee-title owner. Corporations, partnerships, and other business entities are expressly permitted to be those owners, to vote as owners, and to designate an individual to serve. There is no requirement that a director be a U.S. citizen or resident. So your U.S. property-holding entity, as landowner of record, can appoint whichever of your principals you choose, including a Taiwan-based individual, as the three-member board.  Power infrastructure limitation. The enacted definition of "public infrastructure" in A.R.S. § 48-7001 does not include electrical power generation or transmission. The reference to electrical facilities appears only as components of lighting and traffic-control systems, and the Legislature removed broader energy infrastructure from the definition during the Senate amendments. A SAID will likely not finance the high-load power infrastructure required for semiconductor fabrication, data storage, or heavy manufacturing.  Water infrastructure within a current utility CC&N. Where water, sewer, or wastewater facilities fall within a regulated utility's certificated service territory, the SAID cannot build or own them without the utility's written consent and must convey them to the utility on completion. Entitlements and zoning: The determination of entitlements, zoning, and other land use permitting, as well as construction permitting for a technology or manufacturing facilities remain with the local jurisdiction and run on a separate track. Our Dorsey team will help you coordinate the financing and entitlement timelines together. Our Dorsey team works regularly with Taiwanese and other Asia-Pacific companies entering the Arizona market. If a SAID fits your project, we can structure it for your cross-border ownership.

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Patent Partners Al Araiza and Lena Petrovic Join Dorsey in Palo Alto

Patent partners Al Araiza and Lena Petrovic have joined Dorsey & Whitney LLP in Palo Alto, the international law firm announced today. Al Araiza works with clients to develop and implement patent strategies that align with corporate objectives, supporting growth initiatives, financing efforts, and successful exits, including initial public offerings and acquisitions. He advises on building, managing, and optimizing patent portfolios across a broad range of emerging and frontier technologies, with depth in wireless communications, artificial intelligence, and energy innovation. Before practicing law, Al gained engineering experience in the defense industry, working on energy system modeling and communications circuitry design. He also conducted biomedical research, with findings published in peer-reviewed journals. He has been recognized in the IAM Patent 1000 for his work advising clients on patent strategy and portfolio development. Al received his J.D. from Duke University School of Law, his M.E. in Biomedical Engineering from Tulane University, and his B.S. in Electrical Engineering from UCLA. Lena Petrovic works across the software and hardware industries to develop clear, well-supported patent applications. She guides clients through the prosecution process and advises on global trademark and copyright matters, including licensing and portfolio management. Lena regularly supports clients developing technologies such as artificial intelligence and machine learning, fintech, cryptography, interactive and immersive experiences, and digital media, and works with companies in entertainment, gaming, and sports. Before practicing law, Lena spent a decade at Pixar, where she contributed to major films including The Incredibles, Ratatouille, WALL‑E, and Brave. Lena received her J.D. from Santa Clara University School of Law, her M.S. in Computer Science from Princeton University, and her B.S. from California Institute of Technology. “Al and Lena bring a practical, technical, and business-focused approach informed by extensive experience working with technology companies, startups, and investors,” said Gina Cornelio, Patent Practice Group Co-Leader. “We are thrilled to welcome them to the Patent team and our growing Palo Alto office.” “Dorsey’s Patent practice is dedicated to understanding each client's business deeply, tailoring patent strategies that directly advance their goals,” said Al Araiza. “We are proud to join this outstanding team and look forward to driving success for our clients.”