After the Supreme Court's reversal in Purdue, Debtors subject to mass tort liability will not be able to reorganize utilizing third party releases under a plan. Prior to Purdue, the Fifth, Ninth, and Tenth Circuits all prohibited third party releases but debtor subject to mass tort liability have nonetheless been able to reorganize. How did those debtors confirm their plans without third party releases? How will mass tort reorganization different after Purdue?