On June 10, the Second Circuit Court of Appeals held in the Quebecor World (USA) Inc. bankruptcy that payments made by a company in purchasing notes issued by an affiliate constituted transfers made in connection with a securities contract.  Therefore, the payments were protected from avoidance by a “safe harbor” under section 546(e) of the Bankruptcy Code.  Orrick covered the Quebecor decision in depth in the linked client memo.  Quebecor Case.