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modification. Specifically, respondent asserts that the 776
patent and 750 patent application provided no consideration
because the 776 patent was a division of patent application S.N.
800,288 ("Method of Making Self-Inflating Air Mattress"), which
was, therefore, assigned to Cascade in 1979, and the 750 patent
application was rejected by the U.S. Patent and Trademark Office.
"We recall the first lesson in contracts, the peppercorn
theory--that courts will not inquire into the adequacy of
consideration so long as it was true and valuable." Pope v.
Savings Bank, 850 F.2d 1345, 1356 (9th Cir. 1988). Here it was.
"Adequacy of consideration" is to be distinguished from the legal
"sufficiency" of any particular consideration. Legal sufficiency
of consideration is concerned not with comparative value but with
that which will support a promise. King County v. Taxpayers, 949
P.2d 1260, 1267 (Wash. 1997); Browning v. Johnson, 422 P.2d 314,
316, amended 430 P.2d 591 (Wash. 1967). The relative values of a
promise and the consideration for it, do not affect the
sufficiency of consideration. See Browning v. Johnson, supra;
Puget Mill Co. v. Kerry, 49 P.2d 57, 64 (Wash. 1935); 3
Williston, Treatise on the Law of Contracts, sec. 7:21, at 383-
386 (4th ed. 1992).
We agree that the 776 patent did not provide new
consideration. The 776 patent was a division of patent
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