The giving an equivalent in value to the obligation. Formerly there was considerable controversy whether or not, in a bill of exchange or promissory note, it was essential to its validity that "value received" should be expressed, and there were old cases which decided in the affirmative. In most States this is not the law at the present time, it being well settled to-day that the words are not necessary, for "value" is implied in every bill, note, acceptance, and indorsement. There is an exception in the case of Missouri, however, where the words " alue received" are essential .to the negotiability of a promissory note. In Pennsylvania, it has long been customary to use the words " without defalcation " in the place of " value received," but the words are non-essential.

The statutes of the State of Michigan declare that: "Every negotiable instrument is deemed prima facie to have been issued for valuable consideration; and every person whose signature appears thereon to have become a party thereto for value."