In re Spearing Tool and Manufacturing Co., Inc.

Crestmark (plaintiff) held a financing agreement secured by all of Spearing Tool's assets, filed under Spearing's exact registered name; the IRS later filed federal tax lien notices against Spearing using a slightly abbreviated name ("SPEARING TOOL & MFG. COMPANY INC."), and the state registry's search technology didn't reveal filings under name variations or abbreviations. When Crestmark's searches under Spearing's exact registered name failed to surface the IRS liens, the registry itself recommended Crestmark also search using the abbreviated variant, but Crestmark didn't do so and continued advancing funds until Spearing's bankruptcy; the bankruptcy court found for the IRS on lien priority, the district court reversed, and the IRS appealed.