January 5, 2017 Lease Rejection Cap Doesn’t Apply to Past-Due Rent Accrued Before Rejection Ninth Circuit refuses to apply Section 506(b)(6) to all damages related to lease claims. 9th Circuit , November 8, 2016 Ninth Circuit Now Requires Paying Default Interest to Cure a Default Divided panel holds that Section 1123(d) overruled Entz-White. 9th Circuit ,