On June 23, 2015, Judge Katherine Polk Failla of the U.S. District Court for the Southern District of New York held that a debt restructuring outside of bankruptcy that deprives dissenting bondholders of assets against which to recover violates Section 316(b) of the Trust Indenture Act of 1939, 15 U.S.C. § 77ppp(b), even if the restructuring does not modify any indenture term explicitly governing the right to receive interest or principal on a certain date. Marblegate Asset Mgmt. v. Educ. Mgmt. Corp., No. 14 Civ. 8584(KPF), 2015 WL 3867643 (S.D.N.Y. June 23, 2015).