In an April 14 opinion, the U.S. Bankruptcy Court for the District of Delaware broke new ground in ruling on how a plaintiff in a preference action may plead compliance with the recently-added "reasonable due diligence" requirement in section 547(b) of the Bankruptcy Code. Agreeing with what it found to be the only other reported decision squarely on point, the Delaware bankruptcy court ruled that a plaintiff need not explicitly plead its "due diligence" in investigating its preference cause of action. Rather, a general allegation under Federal Rule of Civil Procedure 9(c) that "all conditions precedent have occurred" suffices.