ABCs

Data sales in ABCs and Chapter 7: what the record shows

Picking between an ABC and Chapter 7 usually comes down to cost, speed and who controls the process. When the company has years of email, Slack and code, a further question matters: which route has actually produced data sales?

AI Data Offers research deskChecked against our methodology Updated October 28, 2026 2 min read 10 sources

In this guide

SimpleClosure

The scorecard by route

Chapter 11
Reported data sales
Spirit Airlines archive ($10.0M winning bid, pending). Character.AI code ($20M stalking horse).
Notes
The only court cases with AI bidders
Chapter 11, consumer data
Reported data sales
23andMe ($305M), Bed Bath & Beyond ($21.5M), RadioShack ($26M IP)
Notes
Customer records with a brand
ABC
Reported data sales
Zulily brand and customer database ($4.5M)
Notes
No reported archive sale to an AI buyer
Chapter 7
Reported data sales
None reported
Notes
Trustee must preserve data quickly
Voluntary wind-down
Reported data sales
150+ deals via SimpleClosure, $10K to $100K typical
Notes
Where most volume is

Route	Reported data sales	Notes
Chapter 11	Spirit Airlines archive ($10.0M winning bid, pending). Character.AI code ($20M stalking horse).	The only court cases with AI bidders
Chapter 11, consumer data	23andMe ($305M), Bed Bath & Beyond ($21.5M), RadioShack ($26M IP)	Customer records with a brand
ABC	Zulily brand and customer database ($4.5M)	No reported archive sale to an AI buyer
Chapter 7	None reported	Trustee must preserve data quickly
Voluntary wind-down	150+ deals via SimpleClosure, $10K to $100K typical	Where most volume is

What this means for the choice

An ABC keeps control with an assignee you choose and can move faster than court, which helps keep systems alive.
Chapter 7 hands control to a trustee who may not know the archive has value. Tell them.
Voluntary wind-downs, before either, are where most data deals close today.

Whatever route you choose, preserve the data first. See the winding-down checklist.

FAQ

Questions, answered

Has any ABC sold an email archive to an AI company?

Not in any reported case we know of. Zulily's ABC sold a customer database with the brand.

Is a data sale easier in an ABC or Chapter 7?

There is no track record for either yet. An ABC keeps control with an assignee you choose, which can make preserving the data easier. Ask counsel.

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Sources

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