In America, there is always another legal chapter.

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The real story, though, is not the probable next chapter in the ongoing legal war between Apple and Samsung, or even if Apple will give Google competition for Google Wallet with NFC.

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Like other recent large airline mergers that have helped U.S. carriers compete more effectively in global markets, the American-US Airways combination was, in several important respects, made possible by Chapter 11 and the legal and financial tools it offers to companies in need.

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But Mr. Butler's relentless activism in the American case is a reminder that bondholders, employees and suppliers have the last legal word on what happens in a Chapter 11 case and can exert their will to influence the outcome.

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The ruling adds another chapter to the long-running legal battle that started when the six suspects were indicted by the United States between 1999 and 2006.

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For its part OptInRealBig describes itself as a premier internet marketing company and said the move to seek Chapter 11 was necessary to let it keep trading while sorting out its legal battles.

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But the key point is that Chapter 11 would have provided an orderly workout, giving the auto makers the legal protection to clean up balance sheets, modify contracts and restructure under due process.

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