Focus Media, Inc. v. National Broadcasting Co. (08/02/04 - No. 03-55808) U.S. 9th Circuit Court of Appeals Plaintiff-Debtor unsuccessfully challenged the Bankruptcy Court's orders granting summary judgment for Defendant where it did not create a triable issue of fact regarding whether defendant's claims were subject to a bona fide dispute and whether Plaintiff was generally paying debts as they became due.