Official Committee of Unsecured Creditors v. EBF Partners, LLC (In re Cornerstone Tower Service, Inc.), Ch. 11, BK16-40787, A17-4050 (Jan. 3, 2019)
The court ruled on summary judgment in a preference action that a "payment rights purchase and sale agreement" executed between the debtor and a funding company during the preference period was a sale of receivables and not a loan. After analyzing U.C.C. law on general intangibles and payment intangibles, the court determined the assets sold were in fact accounts and not intangibles, and the creditor's interest was unperfected, so the assets were property of the bankruptcy estate.