According to the The purchase-money security interest (“PMSI”) can give a creditor the first priority security interest in goods that it enabled the debtor to acquire, even if other lenders hold prior perfected security interests in the same collateral. However, because this is an exception to the general “first to file” priority rule, secured parties must strictly comply with the Article 9 PMSI requirements. The recent case of T. Gluck & Co., Inc. v. Craig Drake Mfg., Inc., 2013 N.Y. Misc. LEXIS 2384 (N.Y. Sup. Ct. June 4, 2013) illustrates the potential risks of PMSI noncompliance for secured parties.