The U.S. Court of Appeals for the Third Circuit recently issued a precedential decision involving a matter of first impression that likely will modify how pharmaceutical and other distributors and their related entities structure their business dealings with manufacturers and others with analogous arrangements. In In re Orexigen Therapeutics, 990 F.3d 748 (3d Cir. 2021), the court affirmed the U.S. District Court for the District of Delaware and the U.S. Bankruptcy Court for the District of Delaware decisions that held that Bankruptcy Code Section 533 does not permit triangular setoffs because they lack mutuality.