In the April 2010 ABF Journal article, “In re Philadelphia Newspapers, LLC: The Not-So-Secured Right to Credit Bid,” Jeffrey Wurst discussed the Third Circuit’s decision that in a sale of assets under a plan of reorganization, a secured lender did not have the right to credit bid. Since then, the Seventh Circuit allowed the secured creditor to credit bid. The resulting U.S. Supreme Court decision in RadLAX held that a sale of assets under a plan cannot prevent a secured creditor from credit bidding.