A trustee is not required to provide actual copies of relevant transaction documents as exhibits to a preference complaint in order to comply with Iqbal.

Where there are multiple debtors in a case, an avoidance complaint must specifically identify the transferrer debtor in order to state a claim.

The complaint must also specifically describe the existence of a debtor/creditor relationship and the nature of the antecedent debt. Mere reference to check numbers, dates and amounts is insufficient.

The limitations period for a §544 avoidance action runs from when the last creditor could reasonably have discovered the fraudulent transfer.

The 2 year limitations period of §548 is a substantive element of the trustee's claim that can't be equitably tolled.

Where a minority investors representative on debtor's board stated that the investor was likely interested in participating in future financing to the debtor, it was not fraud where the investor ultimately declined to do so.

Where a minority investor's representative's level of personal involvement with the debtor corporation's affairs was no different than what would be expected from a corporate director, the minority investor did not "actually control" the debtor, and did not owe a fiduciary duty to the debtor.