Seven separate objections were filed by Monday’s deadline against the proposed settlement between USA Cricket and American Cricket Enterprises and the related $480,000 in post-petition financing the settlement depends on. They came from the National Cricket League, recent/former USA Cricket Chairman Venu Pisike, former Board member and Executive Secretary Anj Balusu, former director Srini Salver, and creditor and former USA Cricket counsel Sesha Kalapatapu. Each filed separately, and they vary in length and emphasis. They do not constitute a unified action, but four substantive arguments recur across them.
Judge Michael E. Romero is scheduled to consider both motions this afternoon at 4 p.m. Eastern time, in a hearing in Denver. What follows summarizes the substance of the objections. It is not an evaluation of their merits, the credibility of the parties making them, or the likelihood of any outcome. The court will weigh those questions today.
There is a competing bid
NCL’s objection turns on a fact that is new to the record this week: the National Cricket League, the Dallas-based T20 and T10 organization that has been operating in tension with ACE’s Major League Cricket, has offered the trustee an alternative.
The offer is attached to NCL’s 11-page objection as an exhibit. NCL’s filing frames the trustee’s settlement as a plan disguised as a settlement — one that, in NCL’s reading, “dictates the outcome of this case, surrenders estate claims without meaningful analysis, forecloses competing financing and restructuring alternatives, and ensures ACE’s anti-competitive control over a developing national market.”
The trustee’s position has been that ACE was the only party with both the financial capacity and the commercial incentive to fund the bankruptcy. NCL’s objection argues that proposition was never genuinely tested. The presence of an actual competing offer changes the question the court is being asked to answer. It is no longer whether the trustee found the only deal available. It is whether the trustee chose between deals.
NCL’s objection also frames the scale of what is at stake. “The settlement agreement would assign exclusive media rights — for 50 years — to a company owned by ACE’s founders (Willow). Over the 50-year life of the ACE Term Sheet, these media rights alone could be worth billions.”
Pisike’s objection makes a parallel point in different terms: arguing that ACE’s willingness to walk away from a $150 million proof of claim is itself evidence of how much ACE values the Term Sheet remaining in force.
ACE may already owe USA Cricket more than the settlement collects
Three of the filings make a version of the same argument: the proposed settlement waives prepetition claims that USA Cricket has against ACE, and those claims are worth substantially more than the $340,000 escrow ACE has agreed to fund.
Pisike’s objection puts a specific number on it. Citing a June 2025 reconciliation between the parties, the filing identifies $404,550 in unpaid player payments, $201,639 in unpaid staff payments, and $647,603 in invoiced 2025 amounts, for a total it states “is no less than $1,253,792.” That figure, the objection argues, “should be the minimum amount paid to USA Cricket for immediate release to its creditors without any strings attached.” Sesha Kalapatapu’s shorter objection identifies “at least $1.2 million” in valid claims that the settlement waives.
The argument behind that number, in Pisike’s framing, is that ACE has been counting the salaries it pays MLC players who are also national team players as discharging ACE’s separate Term Sheet obligation to fund USA National Team operations. “ACE is essentially using USA Cricket to fund its MLC player salaries, which is contrary to the plain language, intent and spirit of the Term Sheet.”
NCL’s objection comes at the same problem from a different angle. The trustee, NCL notes, has not formally objected to ACE’s $150 million proof of claim, has not asked the court to estimate it, and has not addressed USA Cricket’s counterclaims. “Did ACE build the stadiums it was contractually obligated to construct? Did ACE pay the fees it was required to pay the Debtor? Did ACE misuse the Debtor’s rights vis-à-vis the International Cricket Council? If these were legitimate problems pre-petition, the Trustee should at least explain why they are not a problem now.”
Whether ACE has performed
The filing of Anj Balusu, the former Executive Secretary of USA Cricket, identifies a specific operational data point regarding ACE’s contractual non-performance: “The most visible recent illustration is the participation of the USA Men’s National Team in a major ICC T20 event without a national-team sponsor in place, despite qualification for the event approximately twenty-four months in advance. A two-year runway is more than sufficient for a commercial partner to secure a primary sponsor for a National Team appearing on the world stage. The absence of one bears directly on whether ACE has been performing the exclusive commercialization function the Term Sheet assigns to it.” Balusu offers, if the court requests it, a sworn declaration with additional detail.
On the physical infrastructure ACE committed to build, Pisike’s objection argues that the High Performance Center, which the Term Sheet required to open by the end of 2020 and was later extended to the end of 2021, has not been built. The objection cites a USA Cricket breach notice issued in early 2024 and ACE’s response that a Prairie View, Texas facility was the contemplated High Performance Center. “These statements were completely false; the Prairie View complex was not owned or developed by ACE.”
On stadiums, where the Term Sheet required six ICC-grade venues by 2024, the objection argues there is no dispute that ACE has not and will not be in compliance, citing as one example ACE’s alleged characterization of the Oakland Coliseum as a developed light-footprint stadium.
Balusu identifies a related pattern. “On multiple occasions during the undersigned’s Board service, ACE obtained waivers or concessions from USA Cricket on amounts otherwise owed to the governing body, on the asserted basis of commercial hardship.” That pattern matters now, the filing argues, because the proposed settlement waives all Term Sheet payment obligations through December 31, 2026 — in effect, another waiver, layered on top of the previous ones, and granted by a trustee who was not present for the earlier ones.
Whether USA Cricket can be what it needs to be under this contract
The structural argument across the filings is that the combination of features in the Term Sheet — not any one of them in isolation — is what creates the problem. Balusu’s objection frames it this way: “The difficulty is not the duration of the term in isolation, the commercial scope in isolation, or the exclusivity in isolation. It is the combination: a multi-decade horizon, exclusivity, operational reach into the National Teams, and exclusive control of revenue, all in the hands of a single party.”
That combination, the objections argue, runs into three different sets of obligations USA Cricket has to entities other than ACE.
The first is its 501(c)(3) status as a public charity. Pisike’s objection argues essentially that a public charity is not allowed to hand over substantial control of its activities to a for-profit partner with independent commercial interests in the same activities — and walks through the Term Sheet’s revenue control, spending approval, and exclusivity provisions to argue the deal does exactly that. Sesha Kalapatapu’s objection makes the same point more succinctly: the motion does not address whether reviving the Term Sheet without modification would cause USA Cricket to operate for a “substantial nonexempt purpose” in violation of federal nonprofit law.
The second is ICC membership. Pisike’s objection notes that the ICC, in 2022 comments on the draft longform deal (that had been negotiated by ACE and USA Cricket to replace the Term Sheet), identified roughly ten provisions it believed could conflict with USA Cricket’s ICC membership obligations — and asserts that “the Trustee has not negotiated or resolved any of these terms with ACE.”
The third is antitrust. Pisike’s objection argues the Term Sheet’s exclusive sanctioning and exclusive commercialization provisions cannot survive antitrust scrutiny because ACE has neither the authority to influence US national team selection nor a track record of actually commercializing the team — “ACE has provided no successful marketing, licensing or other agreements regarding the USA National Team since the Term Sheet was signed” — yet the exclusivity prevents USA Cricket from doing it itself.
Salver’s shorter filing approaches the problem from a different direction. The Term Sheet was terminated by USA Cricket prepetition. If it was fully terminated, Salver argues, it may not be a contract that exists for the trustee to assume in the first place — reinstatement under the settlement may effectively be a new agreement, requiring different procedural treatment than what the trustee has put before the court.
What the financing actually funds
Balusu’s objection includes a separate critique of the proposed financing budget itself. The $480,000 in post-petition funding allocates approximately $385,000 to bankruptcy-related professional costs (legal, accounting, trustee fees) and only $114,000 to operating expenses across the funding period — with effectively nothing for player support, member services, competition operations, or sport development. “ICC reinstatement turns, in part, on the governing body’s ability to demonstrate that it can develop the sport, support its players, run its competitions, and serve its members. A budget that funds the case but not those functions risks preserving the legal entity while leaving the underlying mission unfunded.”
Pisike’s parallel financing objection makes a related point. The trustee’s motion presents ACE as the only viable lender. Pisike argues alternatives existed and were not pursued: a group of individuals offering to generate revenue by managing operations met with the trustee but received no follow-up; the ICC previously represented to the court that it would offer post-petition funding on the condition that the prior Board step down, a condition Pisike argues is now satisfied by the trustee’s appointment; and ACE’s counsel attempted to negotiate funding with USA Cricket’s prepetition counsel, Mark Billion, and prepetition CEO, Jonathan Atkeison, on terms Pisike asserts “were better than the terms that the Trustee now asks the Court to accept.”
Two notable absences
The ICC, represented in the case by Stinson LLP, did not file an objection. The settlement’s requirement that the contemplated long-form agreement “address the concerns and comments raised by ICC to ACE prepetition” does not, on the May 4 record, appear to have generated a concurrent ICC objection to the settlement itself. Whether ICC takes a position at the hearing is unknown.
The dissident director group — Whittaker, Nijjar, Gona, and Rai — also did not file. These are the four directors who have been suing the Pisike majority in Colorado state court since March 2025 in litigation that survived a motion to dismiss in June 2025 and is now in discovery. Their opposition during the Pisike era to the August 2025 ACE termination vote, and their broader posture on USA Cricket governance, would have made them plausible objectors.
What gets decided this afternoon
The trustee’s timeline anticipates that approval orders will be entered today, with a chapter 11 plan filed the week of May 22 and confirmation targeted for the week of June 26. ACE’s commitment to provide exit financing, its agreement to dismiss its arbitration and state-court proceedings, and its withdrawal of the $150 million proof of claim are all conditioned on entry of the approval order. So is the trustee’s ability to access the $480,000 in financing.
None of the seven objections disputes that USA Cricket needs financing and a path out of bankruptcy. What they dispute is whether the financing and emergence on offer — conditioned on assumption of a 50-year exclusive contract that several objectors say is itself the source of the underlying problem — is the right deal.
The presence of an alternative bidder, the unresolved question of how much ACE owes USA Cricket, and the documented gap between what ACE committed to build and what is actually built are all on the record now in a way they were not before Monday. So is the silence of two parties who might have been expected to be heard. What the court does with that record is what this afternoon’s session will answer.
