DZ Bank AG Deutsche Zentral-Genossenschaftsbank v. Connect Insurance Agency, Inc.
United States District Court for the Western District of Washington
2016 WL 631574 (2016)
- Written by Joe Cox, JD
Facts
DZ Bank Ag Deutsche Zentral-Genossenschaftsbank (DZ Bank) (plaintiff) held a security interest in certain collateral that was perfected in Washington by DZ Bank’s filing of a financing statement. Connect Insurance Agency, Inc. (Connect) (defendant) purchased some of that collateral in Washington and then moved some of the collateral to Texas and some to Florida. DZ Bank sued Connect, and the question of the applicability of DZ Bank’s Washington perfection to the collateral in Texas or Florida was raised. DZ Bank had not filed financing statements in either Texas or Florida, and Connect argued that because DZ Bank had not done so, it no longer had valid security interests against the possessory interests of Connect. There was no Washington caselaw interpreting the relevant UCC provision, so the court considering this matter largely relied on commentaries and cases from other jurisdictions.
Rule of Law
Issue
Holding and Reasoning (Robart, J.)
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