Puritan Finance v. Bechstein Construction

A claim does not accrue under Section 9-404(a)(2) of the UCC until a cause of action has accrued. Even though defendant construction company had performed services for cartage company prior to its assignment of its accounts receivable, no cause of action had accrued against cartage company, and thus defendant could not rely on those services as basis for setoff against plaintiff assignee's claim. (HALL and KARNEZIS, concurring.)