M executed a negotiable note payable to the order of P, secured by a mortgage. After maturity, P assigned the note and mortgage without his indorsement to X for value. Y procured an assignment of these from X by fraud and in turn assigned them to Z, a purchaser without notice and for value. In Z's suit to foreclose the mortgage, X intervened, demanding the delivery of the same to himself. Held, Z's bona fide purchase cut off X's latent equity. Frank v. Brown, 255 Mich. 415, 238 N. W. 237 (1931).