This case raises “two issues of vital public policy and legal importance … that extend far beyond the particular facts of this case.” App. 169–70 (U.S. Br.); Brazil Br. 7 (“utmost import to the international order”); France Br. 11 (“global impact”); Mexico Br. 1 (“jeopardize[s] the economy of a sovereign nation”). Because no sovereign bankruptcy regime exists, voluntarily restructuring is critical for Nations in crisis to obtain some fresh start while also protecting creditors.

REPLY BRIEF
This case raises “two issues of vital public policy 
and legal importance … that extend far beyond the 
particular facts of this case.” App. 169–70 (U.S. Br.); 
Brazil Br. 7 (“utmost import to the international 
order”); France Br. 11 (“global impact”); Mexico Br. 1 
(“jeopardize[s] the economy of a sovereign nation”). 
Because no sovereign bankruptcy regime exists, 
voluntarily restructuring is critical for Nations in 
crisis to obtain some fresh start while also protecting 
creditors. Stiglitz Br. 1–2. Respondents’ effort to
treat Argentina’s restructuring as malum in se thus
blinks reality. Creditors can hold out, but the
Foreign Sovereign Immunities Act (“FSIA”), 28
U.S.C. §§ 1609–1611, limits their ability to enforce
judgments.
The decisions below turn this system on its head.
The injunctions empower holdouts to profit off the
exchange bondholders’ sacrifice, mandating payment
in full—including to vulture funds that purchased
bonds post-default for pennies on the dollar. And to
coerce payment, the injunctions hold hostage the 92%
of bondholders who participated in the restructuring
by taking substantial haircuts. If Respondents’
gambit succeeds here, it will make restructuring
“substantially more difficult, if not impossible.” App.
182 (U.S. Br.).
Respondents1 argue that this Court should deny
certiorari because Argentina will disregard any
adverse order. Respondents are doubly wrong. A

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