1944 Beach Boulevard, LLC v. Live Oak Banking Company
On certified questions from the Eleventh Circuit about the scope of a 'search' under the UCC financing-statement safe harbor, the Florida Supreme Court instead resolved a threshold question: the safe harbor of section 679.5061(3) applies only if the filing office employs a 'standard search logic.' Adopting the industry definition (a procedure that unambiguously identifies specific 'hits'), the Court held that the Florida Secured Transaction Registry's search option—which returns a browsable index of the entire database rather than a finite set of hits—is not a standard search logic. Consequently, the safe harbor cannot apply, and the zero-tolerance rule of section 679.5061(2) governs: any financing statement that fails to correctly name the debtor under section 679.5031(1) is seriously misleading and ineffective.
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