Except in very limited circumstances, a creditor of a bankrupt debtor must file a claim in order to secure any chance of recovery. The decision to file, however, is full of strategic considerations, including whether doing so will submit the creditor to bankruptcy court jurisdiction thereby limiting where litigation of the claim will occur. A recent case of first impression from the U.S. Court of Appeals for the Third Circuit provides guidance on this important decision for those claims that arise during the period between plan confirmation and the plan's effective date. See Ellis v. Westinghouse Electric, 2021 U.S. App. LEXIS 26092 (3d Cir. Aug. 30, 2021).