Campbell v. The Hanover Insurance Company

(1) Whether a party asserting a "new value" defense to a preference claim pursuant to 11 U.S.C. § 547(c)(1) must prove the specific value "in money or money"s worth" of the assets transferred to the debtor, as the Third, Fifth, Ninth, Tenth and Eleventh Circuits have held, or a mere approximation of value, as the Fourth Circuit below and the Eighth Circuit, as well as inconsistent Third and Tenth Circuit decisions, have held.