The premise is simple. A retailer is a tenant under an unexpired non-residential real property lease with a shopping center landlord. The tenant files a voluntary bankruptcy petition and becomes a debtor under Title 11 of the United States Code. Once the bankruptcy is filed, the debtor must pay the shopping center landlord rent (i.e., minimum rent and all additional rent under the lease) for its use and occupancy of the premises under § 365 of the Bankruptcy Code (11 U.S.C. § 101, et seq.) until the lease is assumed or rejected.