In In re Physiotherapy Holdings, Inc., 506 B.R. 619 (Bankr. D. Del. 2014) (No. 13-12965), the debtor had entered into several agreements with a consulting company to license certain software.  Pursuant to Section 365(a) of the Bankruptcy Code, the debtor sought to assume one of those agreements – the software license – but reject the other agreements, including the master agreement.  The master agreement required the debtor to indemnify the consulting company for a wide range of liability including significant post-confirmation litigation.  The consulting company argued that the debtor could not assume the license agreement without assuming the other agreements because the agreements together formed a single, integrated contract.  The court disagreed and held that the agreements were not a single, integrated contract because (1) the parties executed the agreements at different times, (2) the agreements provided that in the event of a conflict, the license agreement trumped the master agreement, and (3) the integration clause in the master agreement simply eliminated parol evidence and did not render the license agreement a “mere component” of the master agreement.  The court also noted that even though the master agreement contained a broad indemnity clause, the license agreement contained a limited one––something that would have been unnecessary had the agreements been integrated.  In light of these provisions, the court concluded that the agreements were independent agreements.  In re Physiotherapy Holdings, a reminder that when entering into multi-agreement relationships, parties should consider whether they want the agreements to be integrated and steps that can be taken to obtain that treatment.