1944 Beach Boulevard, LLC v. Live Oak Banking Company

Summary

The court held that the safe harbor for incorrectly named debtors applies only when the filing office uses a standard search logic that identifies specific financing-statement hits. Because Florida's filing registry returns an index rather than definite search hits, the safe harbor was unavailable, making the financing statements seriously misleading and ineffective. The court therefore declined to answer the three certified questions and returned the case to the certifying court.