Sass v. Vector Consulting Inc. (In re American Home Mortg. Holdings Inc.)

Ruling: 
Preference period payments made pursuant to professional service agreement that conformed to industry standards were within ordinary course of business exception to avoidance.
Procedural posture: 
Plaintiff Official Committee of Unsecured Creditors filed a complaint against defendant creditor seeking to avoid and recover four payments as preferential transfers pursuant to 11 U.S.C.S. § 547(b). The chapter 11 plan trustee was substituted as plaintiff. The creditor asserted that it had a complete ordinary course of business defense under § 547(c)(2) and to a limited extent, a new value defense under § 547(c)(4) and/or (c)(1).
Issue: 
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Commercial case opionion summary, case decided on June 05,2012, LexisNexis #0612-125