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232 to participate as a "party in interest" in a U.S. bankruptcy proceeding regarding the debtor. 11 U.S.C. §§ 1524, 1512. Conversely, Chapter 15 may be the only means for a foreign debtor to obtain the benefit of foreign insolvency orders in a U.S. court. See Halo Creative Design Ltd. v. Comptoire Des Indes Inc., 2018 WL 4742066 (N.D.Ill. Oct. 2, 2018) (denying enforcement of automatic stay in Canadian insolvency proceeding because Canadian debtor had not obtained Chapter 15 recognition); OakPoint Partners, Inc. v. Lessing, 2013 WL 1703382 (N.D. Cal. Apr. 19, 2013) (German foreign representative could not use pendency of German insolvency proceeding as defense to U.S. claim against the debtor absent Chapter 15 recognition). An exception to this limitation on access to the U.S. courts is found in Section 1509(f), which permits a foreign representative to commence a collection action without first filing a petition for, or gaining, recognition of a foreign proceeding. One potential consequence of the requirement that the foreign representative must obtain Chapter 15 recognition before participating in U.S. litigation is that, when combined with the new venue rules for ancillary proceedings (discussed above in Chapter II.B.2.), the foreign representative may be required to commence a Chapter 15 case in a court far from the venue in which the action in which it seeks to intervene is pending. D. Involvement of U.S. Bankruptcy Estate Abroad Chapter 15 also addresses the situation where the representative of a U.S. bankruptcy estate, such as a trustee or examiner, seeks to act abroad on behalf of the U.S. bankruptcy estate. In particular, any such action is only permitted with the authorization of the U.S. court. 11 U.S.C. § 1505. E. Coordination of Concurrent U.S. and Foreign Proceedings Chapter 15 contains various provisions dealing with concurrent proceedings in the U.S. and abroad. For example, once a foreign main proceeding has been recognized, a plenary case on

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