Rick Mitchell discussed in an April 2009 International Financial Law Review article the negotiation of exchange offers by companies that need short-term cash and debt restructuring. "An exchange offer cuts through all jurisdictional conflicts because it is not a compulsory proceeding like an insolvency – it's entirely consensual," he explained. "It's super-charged cash, because you're not only reducing your debt, you're changing the terms of that debt." He added that exchange offers are likely to become more common. "We'll start to see people who are clever, and courageous in some cases, buying in at 15 cents on the dollar and selling to the company at 30."