If it's not done through a chapter 11 bankruptcy, what's the point? Why would you go through the extra step of dissolving the company and not just carry on the business as is? Do you have any examples of where this has been done without a chapter 11 bankruptcy?
You have to keep in mind that Lee is very dissatisfied with the fact that he doesn't own a super majority. The primary motivation seems to be about complete control over the company.
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