collab9, LLC, a Delaware limited liability company

I. Facts and Summary of Pleadings

A. Background On March 19, 2021, Collab9, LLC (the "Debtor") filed its chapter 11 petition. The Debtor is a cloud security service provider for managed voice, collaboration, conferencing, and contact center services primarily for U.S. public sector customers. The Debtor has a special governmental authorization, known as FedRAMP, that certifies that the Debtor’s services are highly secure and may be used by government agencies. Some of the Debtor’s customers include the United States Customs and Border Protection and the Defense Nuclear Facilities Safety Board. First Schatzle Decl. at ¶ 23.

The Debtor states that its business operations have been severely undermined by Avaya, its largest creditor. The Debtor’s relationship with Avaya began in 2017 when it executed an agreement whereby the Debtor would sell its services to Avaya, and Avaya would resell those services to its own customers (the “Master Agreement”). Id. at ¶¶ 59 & 61. In May of 2019, Avaya loaned the Debtor $10,000,000 under a convertible secured note in order to create a system that would streamline the relationship between the Debtor and Avaya/Avaya’s customers. Id. at ¶ 61. The…