Arkansas- Missouri Forest Products, LLC (Ark-Mo), sells suppli make wood pallets. Blue Chip Manufacturing (BCM) makes pallets. Mark Garnett, an owner of Ark-Mo, and Stuar an owner of BCM, went into business together. Garnett and Lerne ship interest in their future projects. When Lerner f Blue Chip Recycling, LLC (BCR), to manage a pallet repair facility in California, however, he allocated only a 5-percent interest to Ark-Mo. Garnett objected. In a "Telephone Deal," Lerner then promised Garnett that Ark-Mo would receive a 30-percent interest in their future projects in the Midwest and Garnett agreed to forgo an ownership interest in BCR But when Blue Chip III, LLC (BC III) a repair facility in the Midwest, Lerner told Garnett that he was not getting anything." Ark-Mo state court against Lerner, alleging breach of contract. Was there consideration to support the Telephone Deal?