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-22- <br />the treatment of Insured Claims and the unsecured deficiency portion of Unaffected Secured <br />Claims (each as more particularly described below). Unaffected Claims are comprised of the <br />following: <br />(a) Claims secured by any of the Charges; <br />(b) All or that portion of a Claim arising from a cause of action for which the <br />applicable insurer or a court of competent jurisdiction has definitively and <br />unconditionally confirmed that the applicable Applicant is insured under an <br />Insurance Policy, to the extent that such Claim is so insured (an "Insured <br />Claim "); <br />(c) Intercompany Claims, <br />(d) Post - Filing Trade Payables; <br />(e) Unaffected Secured Claims, being (i) the Prior Ranking Secured Claims; and (ii) <br />all other Claims against one or more of the Applicants that (a) are secured by a <br />valid security interest over assets or property of the Applicants and (b) the <br />Applicants have identified to the Monitor in writing prior to the Plan <br />Implementation Date as Unaffected Claims under the Plan; <br />(f) Claims by a Person that has been designated by the Applicants, with the consent <br />of the Monitor, as a critical supplier in accordance with the Initial Order which <br />arise from an Unaffected Trade Claim; <br />(g) Claims that are not permitted to be compromised pursuant to section 19(2) of the <br />CCAA; <br />