must: (i) give value, (ii) without knowledge of the security interest, and (iii) before perfection. 1. Value and Perfection The Court can dispose of the value and perfection prongs of the BFV defense here in summary fashion. “Value” under § 9-317 is any consideration sufficient to support a simple contract. U.C.C. §§ 1-202(b), 9-317. It cannot be seriously argued that “value” was not given under these contracts. Traditional contracts law teaches that a mere peppercorn suffices as consideration. See Restatement (Second) of Contracts § 71 (1981) (stating that all that is required for consideration is a bargained-for exchange); Id. § 79 cmt. C (“[C]ourts do not inquire into the adequacy of consideration.”); First Mortgage Co. of Pa. v. Fed. Leasing Corp., 456 A.2d 794, 797 (Del.1982) (<HOLDING>). In fact, the Producers concede that extension
holding that where guaranty and mortgage were not executed simultaneously even a trifling inconvenience to the guarantee constitutes sufficient consideration holding that illiteracy is not of itself sufficient to prove fraud holding that the loss of a statute of limitations defense constitutes clear legal prejudice holding that incurring a legal detriment in and of itself constitutes sufficient consideration holding that the repayment of an antecedent debt constitutes fair consideration