HTML Document View

Full title: Statement of the Official Committee of Unsecured Creditors of Wave Computing, Inc. Regarding (I) the Fifth Amended Joint Chapter 11 Plan of Reorganization for Wave Computing, Inc. and Its Debtor Affiliates and Related Documents and (II) the Plan Supplement (RE: related document(s)1063 Amended Chapter 11 Plan). Filed by Creditor Committee Official Committee of Unsecured Creditors of Wave Computing, Inc. (Wynne, Richard) (Entered: 01/25/2021)

Document posted on Jan 24, 2021 in the bankruptcy, 3 pages and 0 tables.

Bankrupt11 Summary (Automatically Generated)

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 of 21 its position with respect to (i) the Fifth Amended Joint Chapter 11 Plan of Reorganization for 22 The Debtors in these chapter 11 cases are Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave 27 Computing (UK) Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC. 28 2 Supplement in Connection with the Fourth Amended Joint Chapter 11 Plan of Reorganization for Wave Computin 1 Wave Computing, Inc. and its affiliated debtors and debtors in possession (the “Debtors”).Almost two weeks later, there remain several material points of difference between10 the Committee, the Debtors and Tallwood Technology Partners, LLC (“Tallwood”) with respect 11 to the Plan and the Plan Supplement.While the 14 Committee will continue to negotiate in good faith to seek to resolve outstanding differences wit15 16 the Debtors and Tallwood, it is vital that the Court and parties in interest know that the 17 Committee has not agreed to the terms of the Fifth Amended Plan or the Plan Supplement, 18 including the LTA Redline.

Page 1

1 Richard L. Wynne (Bar No. 120349) 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. 8 9 UNITED STATES BANKRUPTCY COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 SAN JOSE DIVISION 12 In re Case No. 20-50682 (MEH) 13 WAVE COMPUTING, INC., et al., Chapter Number 11 (Jointly Administered) 14 Debtors.1 STATEMENT OF THE OFFICIAL 15 COMMITTEE OF UNSECURED CREDITORS OF WAVE COMPUTING, INC. REGARDING (I 16 THE FIFTH AMENDED JOINT CHAPTER 11 PLAN OF REORGANIZATION FOR WAVE 17 COMPUTING, INC. AND ITS DEBTOR AFFILIATES AND RELATED DOCUMENTS 18 AND (II) THE PLAN SUPPLEMENT 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 of 21 its position with respect to (i) the Fifth Amended Joint Chapter 11 Plan of Reorganization for 22 Wave Computing, Inc. and Its Debtor Affiliates [Dkt. No. 1063] (the “Fifth Amended Plan”) and 23 (ii) the Plan Supplement,2 including the Amended Notice Regarding Amended Notice of Redline 24 of Exhibit “E” to the Debtors’ Plan Supplement [Dkt. No. 1068] (the “LTA Redline”), filed by 25 26 1 The Debtors in these chapter 11 cases are Wave Computing, Inc., MIPS Tech, Inc., Hellosoft, Inc., Wave 27 Computing (UK) Limited, Imagination Technologies, Inc., Caustic Graphics, Inc., and MIPS Tech, LLC. The Debtors’ mailing address is 3201 Scott Blvd, Santa Clara, CA 95054. 28 2 Supplement in Connection with the Fourth Amended Joint Chapter 11 Plan of Reorganization for Wave Computin

Page 2

1 Wave Computing, Inc. and its affiliated debtors and debtors in possession (the “Debtors”). 2 On January 12, 2021, the Committee filed the Statement of the Official Committee of 3 Unsecured Creditors of Wave Computing, Inc. Regarding Supplement in Connection With the 4 Fourth Amended Joint Chapter 11 Plan of Reorganization for Wave Computing, Inc. and Its 5 Debtor Affiliates dated Dec. 1, 2020 [Dkt. No. 1042] (the “January 12 Statement”). In the 6 January 12 Statement, the Committee informed the Court and parties in interest that the 7 8 Committee had not agreed to the terms of several of the documents embodied in the Plan 9 Supplement. Almost two weeks later, there remain several material points of difference between10 the Committee, the Debtors and Tallwood Technology Partners, LLC (“Tallwood”) with respect 11 to the Plan and the Plan Supplement. 12 Although the Committee is a co-proponent of the Plan, the Debtors filed the Fifth 13 Amended Plan and the LTA Redline without obtaining the Committee’s consent. While the 14 Committee will continue to negotiate in good faith to seek to resolve outstanding differences wit15 16 the Debtors and Tallwood, it is vital that the Court and parties in interest know that the 17 Committee has not agreed to the terms of the Fifth Amended Plan or the Plan Supplement, 18 including the LTA Redline. 19 The Committee reserves all of its rights. 20 [Signature Page Follows] 21 22 23 24 25 26 27 28

Page 3

1 Respectfully submitted, 2 Dated: January 25, 2021 HOGAN LOVELLS US LLP 3 By: /s/ Richard L. Wynne 4 Richard L. Wynne (Bar No. 120349) richard.wynne@hoganlovells.com 5 David P. Simonds (Bar No. 214499) david.simonds@hoganlovells.com 6 Edward J. McNeilly (Bar No. 314588) edward.mcneilly@hoganlovells.com 7 1999 Avenue of the Stars, Suite 1400 8 Los Angeles, California 90067 Telephone: (310) 785-4600 9 Facsimile: (310) 785-4601 10 Attorneys for the Official Committee of 11 Unsecured Creditors of Wave Computing, Inc. 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28