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| Name | RFC Capital Corporation v. EarthLink, Inc. Case Brief Summary | Law Case Explained |
| Video Uploader | Video From Quimbee |
| Upload Date | This Video Uploaded At 06-06-2023 18:10:43 |
| Video Discription | Get more case briefs explained with Quimbee. Quimbee has over 35,900 case briefs (and counting) keyed to 984 casebooks ► https://www.quimbee.com/case-briefs-overview RFC Capital Corporation v. EarthLink, Inc. | 2004 Ohio 7046, 55 UCC Rep. Serv. 2d 617 (2004) Under the Uniform Commercial Code, or U C C, a debtor’s disposition of collateral doesn’t generally terminate a secured party’s interest without that party’s consent. In R F C Capital Corporation versus Earth Link, Incorporated, the court considered whether a secured creditor that conditionally agrees to release its interest does so by authorizing a collateral sale before the condition has been satisfied. In two thousand, R F C Capital Corporation, which we’ll refer to as Capital, issued Internet Commerce and Communications, Incorporated a loan in exchange for a security interest in Internet Commerce’s customer base. Under the agreement, Internet Commerce couldn’t dispose of its customer base without Capital’s consent. Capital filed a U C C financing statement to record its security interest. Internet Commerce later contracted to sell its customer base to Earth Link, Incorporated. That agreement and Internet Commerce’s oral statements to Earth Link acknowledged Capital’s security interest and claimed that Capital had agreed to release its interest after the sale. However, that wasn’t true at the time. Once Internet Commerce did inform Capital of the sale, the two executed an amendment to their security agreement in which Capital consented to the sale and agreed to release its security interest after Internet Commerce satisfied its loan obligations. Thereafter, Earth Link received the customer base but ultimately acquired only about sixty percent of the customers for which it agreed to pay. Earth Link, accordingly, stopped making payments to Internet Commerce. In turn, Internet Commerce couldn’t satisfy its loan obligations, and therefore, Capital never released its security interest. Capital sued Earth Link for several claims, including impairment of its security interest. Capital claimed specifically that Earth Link took and damaged its collateral without obtaining a release of Capital’s interest. A jury found in Capital’s favor. The trial court denied Earth Link’s motion for a directed verdict. Earth Link appealed, arguing, in part, that Capital had consented to Earth Link’s purchase of the customer base and therefore had agreed to release its security interest by executing the amended security agreement. Want more details on this case? Get the rule of law, issues, holding and reasonings, and more case facts here: https://www.quimbee.com/cases/rfc-capital-corp-v-earthlink-inc The Quimbee App features over 16,300 case briefs keyed to 223 casebooks. Try it free for 7 days! ► https://www.quimbee.com/case-briefs-overview Have Questions about this Case? Submit your questions and get answers from a real attorney here: https://www.quimbee.com/cases/rfc-capital-corp-v-earthlink-inc Did we just become best friends? Stay connected to Quimbee here: Subscribe to our YouTube Channel ► https://www.youtube.com/subscription_center?add_user=QuimbeeDotCom Quimbee Case Brief App ► https://www.quimbee.com/case-briefs-overview Facebook ► https://www.facebook.com/quimbeedotcom/ Twitter ► https://twitter.com/quimbeedotcom #casebriefs #lawcases #casesummaries |
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