In re Maxwell Communication Corp. PLC

Maxwell Communication Corp. (debtor), a large international communications company incorporated in England and controlled, governed, and managed there by British executives and a British board, filed for chapter 11 reorganization in U.S. bankruptcy court and simultaneously petitioned for the equivalent administration proceeding in England, with the American judge and English justice coordinating parallel proceedings. Before either filing, Maxwell had transferred roughly $100 million to two British banks and a French bank, all negotiated and administered in England. Maxwell sought to avoid these transfers, and the parties disputed whether U.S. or English law governed that effort.