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Navigating Jurisdictional Pitfalls: Lessons From Global One Media, Inc. v. Newtek Small Business Finance, LLC on Lien Filing...

The Ninth Circuit Bankruptcy Appellate panel recently reaffirmed the longstanding principle that a UCC-1 financing statement securing personal property must be filed at the debtor’s location. In a recent case, the lender did...more

Lender Beware: Two Recent Bankruptcy Cases Highlight Importance of Diligence in UCC-1 Filings

Lenders should view as cautionary tales two recently handed down decisions regarding UCC-1 financing statements and the perfection of security interests. On December 20, 2019, the U.S. Bankruptcy Court for the District of...more

A Win for Lenders: Seventh Circuit Finds UCC-1 Collateral Description Reference Sufficient

In a win for lenders, on September 11, the U.S. Court of Appeals for the Seventh Circuit reversed the U.S. Bankruptcy Court for the Central District of Illinois, holding that the collateral description in the UCC-1 financing...more

Ambiguous UCC Collateral Descriptions Part II: Another Snare for Private Equity Companies

On August 20, the U.S. Bankruptcy Court for the Central District of Illinois in In re I80 Equipment, LLC, No.17-81749, 2018 WL 4006294 (Bankr. C.D. Ill. Aug. 20, 2018) held that a secured party failed to perfect its security...more

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