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Retailer sold Consumer a refrigerator, a home theater system, and a motorcycle for personal use. Consumer signed a retail installment contract granting Retailer a purchase-money security interest in each item. Retailer did not file a financing statement for the refrigerator or home theater system. For the motorcycle, Retailer filed a financing statement in the central filing office but did not have its lien noted on the certificate of title, even though state law requires notation of security interests on motorcycle titles.
Consumer defaulted. Retailer argues that all three security interests were automatically perfected as purchase-money security interests in consumer goods. Consumer argues that the refrigerator and home theater system may be different from the titled motorcycle and that ordinary filing did not perfect the motorcycle interest.
Discuss whether Retailer perfected its security interests in the refrigerator, home theater system, and motorcycle.