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Grumman Credit Corporation appealed a bankruptcy court ruling that its security interests in six vans leased to Circus Time were unperfected. The bankruptcy court found Grumman failed to comply with Maine and New Hampshire certificate of title acts, which require the title to list the owner and any lienholders along with the date of the lien. However, case law establishes that substantial compliance with notice filing requirements is sufficient to perfect a security interest. Minor errors that are not serio

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