Full title: Statement of the Official Committee of Unsecured Creditors of Wave Computing, Inc. Regarding Supplement in Connection With the Fourth Amended Joint Chapter 11 Plan of Reorganization for Wave Computing, Inc. and Its Debtor Affiliates dated Dec. 1, 2020 (RE: related document(s)1035 Notice). Filed by Creditor Committee Official Committee of Unsecured Creditors of Wave Computing, Inc. (Wynne, Richard) (Entered: 01/12/2021)
Document posted on Jan 11, 2021 in the bankruptcy, 2 pages and 0 tables.
Bankrupt11 Summary (Automatically Generated)
In re Case No. 20-50682 (MEH)
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WAVE COMPUTING, INC., et al., Chapter Number 11 (Jointly Administered) 14
Debtors.1 STATEMENT OF THE OFFICIAL
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COMMITTEE OF UNSECURED CREDITOR
OF WAVE COMPUTING, INC.The Official Committee of Unsecured Creditors of Wave Computing, Inc. (the 20
“Committee”) hereby submits this statement to give notice to the Court and parties in interest 21
regarding the status of the Supplement in Connection with the Fourth Amended Joint Chapter 22
The Committee has not agreed to the terms of several of the documents embodied in th25
26 The Debtors in these chapter 11 cases are Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave
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Technology Partners, LLC (“Tallwood”) with respect to (i) the Exit Facility Agreement (Exhib3
A), (ii) the Senior Secured Note (Exhibit G), (iii) the GUC Loan and Payment Schedule (Exhib4
H), (iv) the Secured Subordinated Note (Exhibit I) and (v) the Intercreditor Agreement (Exhibi5
P) (collectively, the “Finance Documents”).
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richard.wynne@hoganlovells.com
2 David Simonds (Bar No. 214499)
david.simonds@hoganlovells.com
3 Edward J. McNeilly (Bar No. 314588)
edward.mcneilly@hoganlovells.com
4 HOGAN LOVELLS US LLP
1999 Avenue of the Stars, Suite 1400
5 Los Angeles, California 90067
Telephone: (310) 785-4600
6 Facsimile: (310) 785-4601
7 Attorneys for the Official Committee of Unsecured
Creditors of Wave Computing, Inc.
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UNITED STATES BANKRUPTCY COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION
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In re Case No. 20-50682 (MEH)
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WAVE COMPUTING, INC., et al., Chapter Number 11 (Jointly Administered) 14
Debtors.1 STATEMENT OF THE OFFICIAL
15
COMMITTEE OF UNSECURED CREDITOR
OF WAVE COMPUTING, INC. REGARDING
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SUPPLEMENT IN CONNECTION WITH TH
FOURTH AMENDED JOINT CHAPTER 11
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PLAN OF REORGANIZATION FOR WAVE
COMPUTING, INC. AND ITS DEBTOR
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AFFILIATES DATED DEC. 1, 2020
19 The Official Committee of Unsecured Creditors of Wave Computing, Inc. (the 20
“Committee”) hereby submits this statement to give notice to the Court and parties in interest 21
regarding the status of the Supplement in Connection with the Fourth Amended Joint Chapter 22
Plan of Reorganization for Wave Computing, Inc. and its Debtor Affiliates Dated Dec. 1, 2020 23
[Dkt. No. 1035] (the “Plan Supplement”).
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The Committee has not agreed to the terms of several of the documents embodied in th25
26 Plan Supplement, which remain subject to ongoing discussion and negotiation. Without 27
1
The Debtors in these chapter 11 cases are Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave
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Technology Partners, LLC (“Tallwood”) with respect to (i) the Exit Facility Agreement (Exhib3
A), (ii) the Senior Secured Note (Exhibit G), (iii) the GUC Loan and Payment Schedule (Exhib4
H), (iv) the Secured Subordinated Note (Exhibit I) and (v) the Intercreditor Agreement (Exhibi5
P) (collectively, the “Finance Documents”). There also remain material outstanding difference6
with respect to the Liquidating Trust Agreement, a placeholder for which was filed at Exhibit 7
8 The Committee will continue to negotiate in good faith to seek to resolve outstanding 9 differences with the Debtors and Tallwood. However, it is vital that the Court and parties in 10
interest know that the Committee has not agreed to the terms of the Finance Documents filed 11
the Plan Supplement. The Committee also reserves it rights to comment on other documents fi12
with the Plan Supplement, including, without limitation, the New Organizational Documents, 13
which the Committee did not have an opportunity to review prior to them being filed.
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The Committee reserves all of its rights.
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16 Respectfully submitted,
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Dated: January 12, 2021 HOGAN LOVELLS US LLP
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By: /s/ Richard L. Wynne
19 Richard L. Wynne (Bar No. 120349)
richard.wynne@hoganlovells.com
20 David P. Simonds (Bar No. 214499)
david.simonds@hoganlovells.com
21 Edward J. McNeilly (Bar No. 314588)
edward.mcneilly@hoganlovells.com
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1999 Avenue of the Stars, Suite 1400
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Los Angeles, California 90067
Telephone: (310) 785-4600
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Facsimile: (310) 785-4601
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Attorneys for the Official Committee of
Unsecured Creditors of Wave Computing, Inc.
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