In re John’s Bean Farm of Homestead, Inc.
United States Bankruptcy Court for the Southern District of Florida
378 B.R. 385 (2007)
Creditor Klein filed a financing statement against "John's Bean Farm of Homestead, Inc." (John's) (defendant) under the incorrect name "John Bean Farms, Inc."; after John's entered bankruptcy, the trustee searched Florida's registry using John's correct legal name, but Klein's statement never appeared on the initial results page and could only be found by clicking the "previous" results button sixty times. The trustee argued Klein's security interest was therefore unperfected as seriously misleading.
Whether a financing statement filed under an incorrect debtor name is seriously misleading, and therefore ineffective, when it can be located in a registry search only after clicking through sixty pages of results.