Bankruptcy Courts have reached different results regarding the scope of the “Cap” on a landlord’s lease rejection claim. The Ninth Circuit, in the case of Kupfer v. Salma (In re Kupfer), 852 F.3d 853 (9th Cir. 2016), provided guidance on this issue. In Kupfer, the Ninth Circuit held that the statutory cap of 11 U.S.C. Section 502(b)(6) on a landlord’s lease rejection damage claim applies only to claims that result directly from the actual termination of the lease. The Ninth C