The unsecured creditors (ALL of them) of which the unsecured notes are a part...don’t see anything until the earnout hits $110 million...IF it ever does. If it does they see 50% of the next $30 million max. So the max total pool is $15 million....THEN it is a question of how much of that would get to the unsecured notes.
But the primary point is an earnout is a contingent payment. It is likely it will be $0...unless really good things happen to the creditors ahead in line.
This is exactly what happen with GM commons who got a contingent equity in the new company that would pay out it certain things happened. They didn’t and got $0.