Ontario · CCAA
Motion Record of the Defendant, Synaptive Medical Inc. – Volume 1 of 2 – dated October 21, 2026
Application / notice of application · 21 October 2026
AI summary
A plain-English summary drawn only from this filing: what it is, why it matters, and the parties, amounts and dates it turns on.
What we verified from this filing8 verified
- secured creditorsnote: DISPUTED: Pacer's counsel's letter of April 29, 2026 stated Synaptive owed this amount, secured by lien. Pacer's later claim is $3,000,000 (statement of claim, page 27) and the claim is said to exceed $2,000,000 and to keep accruing (page 9). Earlier, the 2025 Monitor's report put Pacer's accrued debt at approximately $1.1 million (page 155). The 2025 and 2026 ARVOs preserve whatever lien rights Pacer may have, with the right to dispute their existence and extent fully reserved. Synaptive disputes the existence of any lien in respect of the Halifax Agreement beyond the Repair and Storage Liens Act (page 26). The movant's position is that all Pacer claims other than lien rights were channelled to ResidualCo. · page: 22 · as of: 2026-04-29 · amount: 1779400 · debtor: Synaptive Medical Inc. · creditor: Pacer Air Freight Ltd. (asserted warehouse lien claimant) · currency: CAD · security: Asserted contractual warehouseman's lien under the Warehousing Agreement and the Repair and Storage Liens Act, over goods and the MRI System stored by Pacer
- unsecured creditorsnote: DISPUTED. Pacer alleges over $2,000,000 owing for transportation and warehousing from May 2024, continuing to accrue monthly (page 9). The $3,000,000 is the amount claimed, not an adjudicated debt. Synaptive's position is that all of this claim (other than preserved lien rights) was channelled to ResidualCo under the 2026 ARVO. The claim is the subject of a summary judgment motion to dismiss. · page: 27 · as of: 2026-09-08 · basis: Statement of Claim issued September 8, 2026 seeking $3,000,000 in damages for breach of contract · amount: 3000000 · debtor: Synaptive Medical Inc. · creditor: Pacer Air Freight Ltd. (damages / unpaid invoices claim) · currency: CAD
- secured creditorsnote: Aggregate for all additional junior noteholders; individual holders not named on these pages. Rank pari passu with the EDC Junior Note. Interest, fees and costs continue to accrue. · page: 81 · as of: 2026-04-28 · amount: 2757249.67 · debtor: Synaptive Medical Inc. · creditor: Additional junior noteholders (prior Synaptive debenture holders) – Additional Junior Notes · currency: USD · security: Junior secured promissory notes; aggregate original principal US$2,579,709.14 at 8.00% p.a.
- secured creditorsnote: Amount stated inclusive of interest and EDC's costs; fees, costs, expenses and interest continue to accrue. Ranks pari passu with the Additional Junior Notes. · page: 81 · as of: 2026-04-28 · amount: 12206353.38 · debtor: Synaptive Medical Inc. · creditor: Export Development Canada (EDC) – Junior Secured Promissory Note · currency: USD · security: General security agreements dated June 26, 2025. Original principal US$11,420,380.87 at 8.00% p.a.
- secured creditorsnote: Amount stated inclusive of interest and EDC's costs; fees, costs, expenses and interest continue to accrue. Rolled-over senior note from the 2025 CCAA transaction (US$6,000,000 principal). · page: 81 · as of: 2026-04-28 · amount: 6412931.51 · debtor: Synaptive Medical Inc. · creditor: Export Development Canada (EDC) – Senior Secured Promissory Note · currency: USD · security: General security agreements dated June 26, 2025; Receiver's counsel opinion that the security is valid and enforceable. Original principal US$6,000,000 at 8.00% p.a.
- secured creditorsnote: Amounts not stated. PPSA equipment financiers (PMSI class); the registrations are described as 'appear to relate', i.e. not confirmed. · page: 82 · debtor: Synaptive Medical Inc. · creditor: De Lage Landen Financial Services Canada Inc. and Hewlett-Packard Financial Services Canada Company · currency: CAD · security: PPSA registrations appearing to relate to financing or lease arrangements for computers, software or related IT assets and, in one case, a forklift
- secured creditorsnote: Amount not stated. The Receiver consented to RBC setting off the card balance against the deposits, with any balance returned to the Receiver. · page: 82 · debtor: Synaptive Medical Inc. · creditor: Royal Bank of Canada (RBC) – credit card facility · currency: CAD · security: PPSA registration; RBC Credit Cards secured by certain RBC GIC deposit accounts
- secured creditorsnote: DISCHARGED: registration is not effective, having been discharged under the Approval and Reverse Vesting Order dated June 18, 2025. Not a current secured claim. · page: 82 · debtor: Synaptive Medical Inc. · creditor: Constantine Zachos · currency: CAD · security: PPSA registration