Timothy R. Zinnecker, Pimzy Whimsy in the Eleventh Circuit: Reflections on In Re Alphatech Systems, Inc., 40 Gonz. L. Rev. 379 (2005).
As a general rule, a priority dispute between holders of competing security interests under Uniform Commercial Code Article 9 (“U.C.C. Article 9”) is resolved in favor of the secured party that was the first creditor to file its financing statement or perfect its security interest. However, a different non-temporal rule may apply if one of the security interests is a purchase-money security interest (“PMSI”). One of these non-temporal rules affords the second-in-time creditor with first-in-line status, the so-called “super-priority” rule, if the creditor has timely perfected a PMSI “in goods other than inventory or livestock.”