By Matthew A. Quick In City of Chicago v Prologis , Tax Increment Financing Bonds (commonly known as "TIF Bonds"), which are created to finance current municipal improvements and are repaid on the tax gain resulting from the improvements, were used to redevelop land bordering O'Hare Airport. The City of Chicago filed a condemnation action to take the property upon which the TIF Bonds had been levied in order to expand the airport. Several parties that held TIF Bonds brought an action to determine the bondholder's stake. The Court held that any loss in a TIF Bond's value resulting from a condemnation proceeding is a consequence of a lawful taking by the government, therefore those holding TIF Bonds are not eligible for just compensation. The Court further opined that those holding the TIF Bonds may not have known of this particular airport expansion, however, the holders of the TIF Bonds could have reasonably foreseen that property bordering airport could have been taken for future airport expansion.