In Triffin v. Pomerantz Staffing Services, 851 A.2d 100 (N.J. Super. 2004), the court held that Friendly's (and Triffin's as its assignee):

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The court held that Friendly's (and Triffin as its assignee) failed to meet the "without notice" requirement, meaning they did not provide timely notice to the drawer (the person who wrote the check) about the dishonored check, which is a necessary step to enforce the check under the New Jersey law applicable to the case.

In Triffin V