The lack of consideration conclusions are the least plausible. The consideration in these cases is continued membership in the conference, with the attendant scheduling etc. conveniences that have value each year, with the added security of a stable conference ensured by a steep GOR penalty for defectors. If membership had zero value, then FSU should have gone independent, or left for another conference. It would have been irrational to do anything but. But FSU stayed. The law in theory only requires a peppercorn as consideration, and FSU got much more than that. The only legs this case might have are via fraud in the inducement imo. Judges don’t appreciate sophisticated parties that seek relief arguing that they signed a deal with no benefit.