Article L. 643-11 of the Commercial Code prohibits the resumption of proceedings against a debtor whose judicial liquidation has been closed for insufficiency of assets. That provision does not, however, apply to so-called “out-of-proceedings” claims, that is to say claims that arose irregularly after the opening judgment. Since they cannot be enforced against the insolvency proceedings, they are not dealt with in the course of the liquidation. Their holder may nevertheless bring a fresh action for payment against the debtor once the insolvency proceedings have ended.