In Plymouth, Rubber. Co. v. West Coast Rubber Co. the creditor was suing for an alleged balance due. The debtor's defense was based on his check, accepted and cashed by the creditor, for part of the account, plus tender of merchandise for the balance. The check was sent with a letter stating in effect that the debtor was unable to dispose of all the goods, purchase of which gave rise to the obligation in question, because the creditor had flooded the local market with inferior goods sold at a lesser price. "We are, therefore, compelled to return these Toesans for credit and ask that you kindly render us credit for whatever we return."
Harold Shepherd & Warren Shattuck,
Accord and Satisfaction in Washington [Part 2],
8 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol8/iss4/2