through its subsidiary, Bakrie Telecom Pte. Ltd. The Notes were governed by New York law. The Indenture Trustee, Bank of New York Mellon, was appointed to represent the interests of noteholders and had the right to submit proofs of claim on their behalf in a restructuring proceeding. The Issuer loaned the proceeds of the Notes to BTEL under an Intercompany Loan Agreement governed by Indonesian law. BTEL's financial difficulties led to defaults on interest payments on the Notes. An Indonesian creditor, PT Netwave Multi Media, initiated a PKPU proceeding in the Indonesian Commercial Court, a court-enforced suspension of payments process designed to facilitate debt restructuring. Creditors, including the Objecting Noteholders, engaged in discussions regarding BTEL's financial and operational situation, ultimately leading to the proposed PKPU Plan. The Issuer, representing a significant portion of the unsecured indebtedness, voted in favor of the PKPU Plan, which was approved by a majority of creditors. A dispute arose over the Issuer's standing to vote and submit claims, as it did so without the consent of the Indenture Trustee. The Objecting Noteholders initiated legal actions in New York, asserting claims of fraud and breach of contract in connection with the Notes offering. The New York court granted summary judgment in favor of the Objecting Noteholders, leading to the Chapter 15 petition filed by BTEL. As a result of the Chapter 15 filing, the parties reached a stipulated judgment in New York, although its enforcement was postponed. The Objecting Noteholders filed a motion to deny recognition of the PKPU Proceeding in the Chapter 15 case. PT Bakrie Telecom Tbk (BTEL), an Indonesian telecommunications company, faced financial difficulties due to a default on payments under certain senior notes. In an attempt to restructure its debt, BTEL initiated a debt restructuring process in Indonesia, known as the "PKPU Proceeding." During this process, a group of noteholders, known as the "Objecting Noteholders," contested the legitimacy of the debt restructuring plan. The Objecting Noteholders claimed that the debt restructuring plan, which included converting a significant portion of the debt into Mandatory Convertible Bonds, was unfair and against their interests. They argued that the restructuring process in Indonesia did not properly consider their rights and that they should have had more say in the outcome. Concurrently, a legal battle took place in New York, where the Objecting Noteholders sued BTEL, its subsidiary, and the Subsidiary Guarantors for breach of contract and fraud related to the debt issuance. The New York court granted summary judgment in favor of the Objecting Noteholders on the breach of contract claim but also ruled that the fraud claims were valid. In response to these legal challenges, BTEL initiated a Chapter 15 bankruptcy case in the United States. The main issue was whether the debt restructuring plan approved in Indonesia should be recognized in the U.S. bankruptcy proceedings. The Objecting Noteholders opposed the recognition, arguing that the plan was fundamentally unfair and that it should not be enforced in the U.S.