As counsel for an ad hoc committee of senior secured noteholders with a $300 million aggregate principal amount, SRZ was instrumental in structuring a plan of reorganization for Foamex International Inc., a leading supplier of flexible foam. The plan provided the noteholders—approximately 10 private equity and hedge funds and other financial institutions—with payment in full of all principal, interest, fees and expenses, as well as a favorable settlement of their claims for a redemption premium. To make the plan work, Foamex received commitments for $940 million in new equity and debt financing that allowed it to satisfy all valid creditors’ claims in full, as well as allowing holders of Foamex’s common stock to retain their ownership interests, subject to dilution. Foamex raised $150 million in new equity through a rights offering to its existing shareholders and received a commitment from a group of lenders for up to $790 million of exit financing.