Richard Carmody is quoted in an article for the American Bankruptcy Institute, "Earmarking Seems to Be a Dead Letter in the Tenth Circuit," noting a recent Tenth Circuit opinion finding that a triangular transaction was a preference. According to the article, "Without saying so, the opinion hints that the so-called earmarking defense to a preference may not hold water in the Tenth Circuit." Richard provided commentary for the article regarding the details of the case.