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RLF1 17847131V.1

UNITED STATES BANKRUPTCY COURT 

DISTRICT OF DELAWARE 

------------------------------------------------------x 

 : 

In re : Chapter 11 

 : 

TK HOLDINGS INC., et al., : Case No. 17-11375 (BLS) 

 : 

 Debtors.1

 : Jointly Administered 

 : 

 : Re: Docket No. 171 

------------------------------------------------------x 

NOTICE OF FILING EXHIBIT B-2 TO MOTION OF DEBTORS PURSUANT TO 11 

U.S.C. §§ 502(B)(9) AND 105(A), FED. R. BANKR. P. 2002, 3003(C)(3), 5005, AND 9007, 

AND LOCAL RULES 2002-1(E), 3001-1, AND 3003-1 FOR AUTHORITY TO (I) 

ESTABLISH DEADLINES FOR FILING PROOFS OF CLAIM, (II) ESTABLISH THE 

FORM AND MANNER OF NOTICE THEREOF, AND (III) APPROVE PROCEDURES 

FOR PROVIDING NOTICE OF BAR DATE AND OTHER IMPORTANT DEADLINES 

AND INFORMATION TO POTENTIAL PSAN INFLATOR CLAIMANTS

 PLEASE TAKE NOTICE that on July 7, 2017, TK Holdings Inc. and its affiliated 

debtors in the above-captioned chapter 11 cases, as debtors and debtors in possession 

(collectively, the “Debtors”) filed the Motion of Debtors Pursuant to 11 U.S.C. §§ 502(b)(9) and 

105(a), Fed. R. Bankr. P. 2002, 3003(c)(3), 5005, and 9007, and Local Rules 2002-1(e), 3001-1, 

and 3003-1 for Authority to (I) Establish Deadlines for Filing Proofs of Claim, (II) Establish the 

Form and Manner of Notice Thereof, and (III) Approve Procedures for Providing Notice of Bar 

Date and Other Important Deadlines and Information to Potential PSAN Inflator Claimants

[Docket No. 171] (the “Motion”). 

 

1

 The Debtors in these chapter 11 cases, along with the last four digits of each Debtor’s federal tax identification 

number, as applicable, are: Takata Americas (9766); TK Finance, LLC (2753); TK China, LLC (1312); TK 

Holdings Inc. (3416); Takata Protection Systems Inc. (3881); Interiors in Flight Inc. (4046); TK Mexico Inc. (8331); 

TK Mexico LLC (9029); TK Holdings de Mexico, S. de R.L. de C.V. (N/A); Industrias Irvin de Mexico, S.A. de 

C.V. (N/A); Takata de Mexico, S.A. de C.V. (N/A); and Strosshe-Mex, S. de R.L. de C.V. (N/A). Except as 

otherwise set forth herein, the Debtors’ international affiliates and subsidiaries are not debtors in these chapter 11 

cases. The location of the Debtors’ corporate headquarters is 2500 Takata Drive, Auburn Hills, Michigan 48326.

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2 

RLF1 17847131V.1

 PLEASE TAKE FURTHER NOTICE that the Debtors are today filing a copy of 

the PPIC Combined Notice,2 a copy of which is attached hereto as Exhibit 1. 

Dated: July 19, 2017 

 Wilmington, Delaware 

/s/ Brett M. Haywood 

RICHARDS, LAYTON & FINGER, P.A. 

Mark D. Collins (No. 2981) 

Michael J. Merchant (No. 3854) 

Amanda R. Steele (No. 5530) 

Brett M. Haywood (No. 6166) 

One Rodney Square 

920 N. King Street 

Wilmington, Delaware 19801 

Telephone: (302) 651-7700 

Facsimile: (302) 651-7701 

-andWEIL, GOTSHAL & MANGES LLP 

Marcia L. Goldstein 

Ronit J. Berkovich 

Matthew P. Goren 

767 Fifth Avenue 

New York, New York 10153 

Telephone: (212) 310-8000 

Facsimile: (212) 310-8007 

Proposed Attorneys for the Debtors 

and Debtors in Possession 

 

2 Capitalized terms used but not otherwise herein defined shall have the meanings ascribed to such terms in the 

Motion.

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RLF1 17847131V.1

Exhibit 1 

PPIC Combined Notice 

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In re: TK HOLDINGS, INC., et al., 

Debtors 

Chapter 11 Case No. 17-11375 (BLS) TK Holdings, Inc. Return M

c/o Prime Clerk P.O. Box 225392 New York, NY 10150 

Credito123456Joe Q. C123 MaMaple V

IMPORTANT LEGAL NOTICE FOR OWNERS OF VEHICLES WITH 

TAKATA AIRBAG INFLATORS 

– This Notice was authorized by a federal court. Read it carefully. 

Your rights are at stake. – 

Why have I received this notice? TK Holdings, Inc. and certain of its affiliates listed on the reverse side of this notice (collectively, the “Debtors”) have filed chapter 11 bankruptcy cases. The Debtors are subsidiaries of Takata Corporation, a Japanese corporation engaged in the manufacture and sale of airbag inflators and other automotive components. Takata Corporation and its worldwide affiliates (including the Debtors) are referred to collectively as “Takata.” You have been identified as the current or former registered owner of a vehicle with one or more Takata-manufactured airbag inflators containing phase-stabilized ammonium nitrate propellant (“PSAN Inflators”), which are or may be defective and could rupture, creating a risk of personal injury or death. This notice sets forth the deadline for asserting claims against the Debtors and provides other important deadlines and information about the chapter 11 cases. Do I have a claim against the Debtors? You (or, in the case of a wrongful-death claim, the estate you represent) may have claims against the Debtors, including for past or future monetary loss, personal injury, or death on account of your current or past ownership of a vehicle containing a PSAN Inflator regardless of whether such PSAN Inflator is subject to a recall or has already been repaired or you have thus far suffered no loss, injury, or death on account of your PSAN Inflator (as such claims may be deemed to have accrued before the Debtors filed for bankruptcy) To assert a claim, you must file a proof of claim by the deadline and in accordance with the instructions on the reverse side of this notice. If you fail to do so, your claim will be barred and you will receive no recovery. What else should I do? The Debtors strongly recommend that you: Carefully review this notice, including the reverse side, in its entirety.  Please visit www.AirbagRecall.com for more information about obtaining replacement airbags.  Register your email address at TKRestructuring.com/PPIC. You will receive no further notices in the chapter 11 cases unless you do so and may miss important 

information. 

 Call 844-822-9240 (U.S. toll-free) or 347-338-6504 (international), email 

takatainfo@primeclerk.com, or visit TKRestructuring.com/PPIC if you have further questions. 

 Contact an attorney for legal advice concerning the chapter 11 cases. 

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Commencement of Chapter 11 Cases. On June 25, 2017 (the “Petition Date”), Debtors Takata Americas; TK Finance, LLC; TK China, LLC; TK Ho

Interiors in Flight Inc.; TK Mexico Inc.; TK Mexico LLC; TK Holdings de Mexico S. de R.L. de C.V.; Industrias Irvin de Mexico, S.A. de C.V.; TakaS. de R.L. de C.V each filed a voluntary petition for relief under chapter 11 of the U.S. Bankruptcy Code in the U.S. Bankruptcy Court for the District imposed an automatic stay against most collection activities. This means that creditors generally may not take action to collect debts from the Debtors 11 cases. Restructuring Proceedings of Debtors’ Japanese Affiliates. Takata Corporation, Takata Kyushu K.K., and Takata Service Corporation (collectivelyunder the Civil Rehabilitation Act (“CRA”) in Tokyo, Japan. Takata Japan intends to seek recognition by the Bankruptcy Court of its CRA proceedinParties who believe they have claims against Takata Japan can obtain information about the CRA proceedings at http://restructuring.primeclerk.com/CFurther Notices. You should register your email address at TKRestructuring.com/PPIC. You will not receive notice of any further documents filed in documents filed with the Bankruptcy Court are available for inspection at the Office of the Clerk of the Court or free of charge at: TKRestructuring.coRestitution Fund: Individuals who have suffered, or will suffer, personal injury caused by the malfunction of a PSAN Inflator may be eligible for comorder of the Federal Court for the E.D. of Michigan. The Court has appointed a Special Master, Prof. Eric D. Green, to administer the claimant compenregarding the distribution of funds. If you believe you may qualify for compensation from the Restitution Funds, please visit www.takataspecialmasterrelevant case documents.Deadline for Filing Proof of Claim. November 27, 2017, at 5:00 p.m. (prevailing Eastern Time) (the “PPIC Bar Date”) is the last date and time to monetary losses, personal injuries (including death), or asserted damages arising out of or relating to an airbag containing a PSAN Inflator manufacturDate (a “PPIC Claim”). You must file a proof of claim for a PPIC Claim (a “PPIC Proof of Claim”) even if you are included in a class action lawsuit oDebtors. Information about how to file a PPIC Proof of Claim, including the ability to file such claim electronically, is available at TKRestructuring.coClaim on or before the PPIC Bar Date: (a) you will be forever barred, estopped, and enjoined from asserting a PPIC Claim against the Debtountil some point in the future; (b) the Debtors and their property shall be forever discharged from any and all indebtedness or liability with rreceive any distribution in these chapter 11 cases on account of such claim. Filing a proof of claim submits a creditor to the jurisdiction of the Banexplain. Plan and Disclosure Statement. The Debtors will soon file a chapter 11 plan of reorganization (the “Plan”) and accompanying disclosure statement (describe the proposed treatment of claims against, and interests in, the Debtors; the Disclosure Statement will provide information about the Plan and thearings to consider, and has set deadlines to object to, the adequacy of the Disclosure Statement and confirmation of the Plan.  Disclosure Statement Hearing. December 4, 2017, with objections due no later than November 27, 2017, at 4:00 p.m. (Prevailing Eastern Time);  Confirmation Hearing. January 23, 2018, with objections due no later than January 16, 2018, at 4:00 p.m. (Prevailing Eastern Time). Carefully review the Plan and Disclosure Statement, available at: TKRestructuring.com. If you register at TKRestructuring.com, you will receive an eStatement and other notices. If you fail to register, this will be the only notice you will receive. The Plan will bind all creditors and interest holders upadequacy of the Disclosure Statement or confirmation of the Plan, you must properly file and serve an objection by the applicable deadline listed abovobjections will be described in the Disclosure Statement. Discharge. Confirmation of the Plan may result in a discharge of debts of the Debtors, which may include all or a part of your debt. See 11 U.S.C. § 1never try to collect against the Debtors, except as provided in the Plan. RELEASES. In addition to the discharge described above, the Plan will likely contain broad releases of third-party claims and related injunccould release claims you hold against certain third parties, including the original equipment manufacturer of your vehicle. The foregoing is a the full text of the Plan’s release and related provisions and any applicable “opt out” provision at [URL]. SALE “FREE AND CLEAR.” The Debtors have proposed Key Safety Systems, Inc. and certain of its subsidiaries and affiliates as their “Plan Sponsor’s acquisition of substantially all assets of the Debtors (with specified exclusions generally related to Takata’s PSAN Inflator businessassets free and clear of all claims, liens, charges, encumbrances, and other interests (collectively, “Claims and Interests”), except for certain spSponsor will not assume any claims of the Debtors or Takata unless it expressly agrees to do so. Without limiting the foregoing, the Plan Sponrelated in any way to the PSAN Inflators (and the propellant), including PPIC Claims. If you do not file an objection to the Plan with the Bankrchallenge the sale of the Debtors’ assets “free and clear” of Claims and Interests will be forfeited. The Bankruptcy Court’s approval of the sale of you will be forever barred from asserting any Claims and Interests against the Plan Sponsor and/or the Plan Sponsor’s predecessors, successors, a

current and former officers and directors, employees, agents, professionals, and various other related persons. You should carefully review the fu

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