Trustee filed an adversary complaint seeking to recover allegedly preferential payments made to defendant by debtor, pursuant to 11 U.S.C. § 547(b). Relying on § 547(c), defendant claimed to have given new value to debtor by releasing its mechanics' lien rights and other claims, in exchange for the payments. Relying on the parties' stipulated facts, the bankruptcy court ruled in favor of trustee, and defendant appealed. The district court rejected defendant's new value defense, concluding that debtor's release of mechanic's liens from property on which debtor, an electrical contractor, had used defendant's supplies had only changed the identity of the holder of the claim against debtor, which does not constitute new value. Any value that was transferred by defendant's releases inured to the owner of the property or its insurer, rather than to debtor's estate. While recognizing that its ruling represented a substantial hardship for the construction industry, the district court indicated that it could not amend the plain meaning of § 547(a). The bankruptcy court's order was affirmed.