In his Commentaries on the Laws of England William Blackstone observed that in the seventeenth century, debtors used simple contracts as one of three accepted forms of unsecured debt instruments.
[5] In 1828, the Parliament of the United Kingdom amended the statute of frauds so that oral acknowledgments or promises could not be used as evidence to prove the existence of a simple contract.
[6] Today, some American jurisdictions have established that a security interest is perfected "when a creditor on a simple contract cannot acquire a judicial lien that is superior to the interest" of the secured party.
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