Despite warnings about the future of the equitable mootness doctrine, courts continue to deny review of challenges to Chapter 11 plans that are confirmed and consummated. Two recent circuit-level decisions, from the First and Third Circuits, determined that appeals of confirmed plans of reorganization were equitably moot despite criticizing the doctrine. Perhaps the case with the right facts has not reached the Courts of Appeals yet. These two decisions suggest that sooner or later reconsideration of the doctrine and meaningful review of bankruptcy court decisions should occur.