if you could overcome this argument you have the case
Any issues with respect to value could have been raised during the Chapter 11 case, and they weren't.
The confirmation of the plan operates as res judicata regarding all matters that should have or could have been raised prior to confirmation. Here, pursuant to the confirmation order, the plan was confirmed on January 27, 2014. In accordance with Bankruptcy Rule 8002, the confirmation order has become final, non-appealable, on or about February 10th of 2014. The effective date did occur back on March 31st, 2014. The plan expressly cancelled and extinguished all equity interests of the Debtors, including this Debtor, and caused all the Debtors' assets to become assets of Reorganized Debtors, free and clear of all liens, claims, and encumbrances.
