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In Corona Fruits and Veggies, Inc v. Frozsun Foods, Inc. 48 Cal. Rptr. 3d 868; 2006 Cal. App., Corona filed a UCC-1 against the debtor name “Armando Munoz”. Debtor’s actual name was “Armando Munoz Juarez”.  This was reflected on his business records, Photo identification card, Green card, tax returns, USDC dealings, and bankruptcy petition.

Frozsun filed a UCC-1 against the debtor name “Armando Juarez”. Its search conducted against the debtor name “Armando Juarez” did not uncover Corona’s UCC filings against “Armando Munoz”. A conflict as to priority of interests arose between two secured parties.

The California appellate court ruled in favor of Frozsun.  The court held that the California and not the Latin American naming conventions were relevant, that in order to be RA9-compliant, the debtor’s last name should have been filed as “Juarez”, not “Munoz”.  If not certain, Corona could have protected itself by using both names on the financing statement.