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P invested $170,000 in companies run by D. Those companies failed, and P and D met over drinks to discuss the matter. D pricked his finger with a safety pin and wrote-in blood (and in Korean)-“Sir, forgive me. Because of my deeds, you have suffered financially. I will repay you to the best of my ability.” P also wrote later that day in ink a promise to pay the monies. A year later, P sued D alleging a default on the promissory note(s). The court ruled in D’s favor because the promise was not supported by consideration and P appealed.

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