Creditor-Plaintiff brought an adversary proceeding under Section 523(a)(2)(A) to except from discharge a debt for fraud, alleging that Debtor fraudulently induced her to personally co-sign a business loan. Plaintiff failed to prove a cause of action for the tort of fraudulent inducement under Illinois law, requiring proof by clear and convincing evidence. A separate debt for contribution between co-makers was established as a matter of state law, but Plaintiff failed to prove that the Debtor made promises that he had no intention of keeping in order to induce her to co-sign the loan, and thus failed to prove by a preponderance of the evidence that the debt should be excepted from discharge.