Security Interests in Goods Held for Lease: The Double Perfection Requirement
Bibliographic record
Abstract
The Canadian provincial and territory Personal Property Security Acts all provide that an unperfected security interest is ineffective against the debtor's trustee in bankruptcy. The PPSAs apply to all transactions that in substance secure payment or performance of an obligation and they extend to any lease for a term of more than one year, in effect deeming the transaction to be a security agreement for the purposes of the statute. In Re Giffen [1998] 1 SCR 91, the Supreme Court of Canada held that the failure of a lessor to perfect its deemed security interest made the security interest ineffective against the lessee's trustee in bankruptcy with the consequence that the lessor could not assert its reversionary title against the trustee. This comment discusses the recent British Columbia Court of Appeal decision in Re Perimeter Transportation Ltd 2010 BCCA 509, where the question was how the above provisions apply where the unperfected lessor has assigned its interest to a third party.
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How this classification was reachedexpand
Full frame machine prediction
Teacher imitationNot calibrated prevalence, not ground truth. Human validation pending. The Gemma side is a direct model label for every work in the frame, read from the title-only record. The Codex side is a classifier learned from the 10,348 direct Codex labels and calibrated to design-weighted sample rates; fields without enough sample support carry no Codex call. Candidate is the union of the two sides; consensus is their intersection. These outputs are machine_predicted_unvalidated and are not human labels.
Distilled classifier scores by category (both heads)
| Category | Codex | Gemma |
|---|---|---|
| Metaresearch | 0.004 | 0.011 |
| Meta-epidemiology (narrow) | 0.000 | 0.001 |
| Meta-epidemiology (broad) | 0.001 | 0.001 |
| Bibliometrics | 0.001 | 0.001 |
| Science and technology studies | 0.004 | 0.011 |
| Scholarly communication | 0.007 | 0.006 |
| Open science | 0.002 | 0.004 |
| Research integrity | 0.008 | 0.006 |
| Insufficient payload (model declined to judge) | 0.011 | 0.002 |
Machine scores (provisional)
The two teacher heads of the student model, read on this work. A score orders the frame for review; it never asserts a category, and the validation status ships verbatim with every row.
Baseline scores from an immature model (maturity gate not passed, 7 training rounds). Scores rank; they never assert a category.
score_only:v0-immature-baseline · verbatim from the scoring run: score_only means the number may rank works, and no category label ships from itClassification
machine, unvalidatedMachine predicted; a candidate call from one source (direct Gemma or distilled Codex), not a consensus.
How this classification was reached, model by model and score by score, is at the end of the page under "How this classification was reached".