A lot of good arguments in the Hybrid Titan Management objection:
a. The Proponents have failed to provide any meaningful information regarding its Reorganized Debtor’s future business. As previously indicated, the Debtor’s business plan consists of a flimsy outline of what appears to be a new company. There are no financial projections that describe in detail the source of revenue, outside funding, operating expenses or marketing and sales plans. Further, there is no mention of the IP, how it will benefit the new business, how it will be maintained, and who will serve as the new CTO.