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PostPosted: Sat Sep 23, 2006 7:07 am 
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In Irby-Greene v. M.O.R., Inc., 79 F.Supp.2d 630 (E.D.Va.2000), this court agreed with the numerous other courts that have followed the language of the commentary to the Holder Rule, holding that “most courts have concluded that the primary purpose of [the Holder Rule] is to provide a defense to claims brought by the creditor; any affirmative use of the clause has generally been limited to the rare situation when the seller's breach renders the transaction practically worthless to the consumer.â€

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