Idaho – In Gugino v. Wells Fargo Bank Northwest, N.A. (In re Lifestyle Home Furnishings, LLC), Case No. 08-00629-TLM, Chapter 7, Adv. No. 08-06103-TLM (U.S. Bankruptcy Court, District of Idaho), decided January 14, 2010, a bank filed a UCC-1, perfecting a security interest in the property of “Factory Direct, LLC”. Thereafter, amended Articles of Organization were filed to change Factory Direct LLC's name to “Lifestyle Home Furnishings, LLC”. The Bankruptcy Court held that under Idaho law the LLC's change of name rendered the financing statement seriously misleading and that the bank had four months to file an amended or new financing statement referencing the debtor's new name. Because the bank did not do so, it no longer had a perfected security interest in collateral acquired by the debtor more than four months after the name change.