| ・ | "Case note regarding an Osaka District Court decision holding that a guarantor may not, without going through the debtor's relevant rehabilitation proceedings, assert a "common benefit claim" (kyoueki-saiken) that the guarantor acquired through a statutory subrogation where such subrogation occurred by way of the guarantor performing its guarantee obligation after such rehabilitation proceedings had been commenced against such rehabilitation debtor," Minji Kensyu No. 639 (July 2010) (co-author) |