sale by a car dealer. Normally, no certificate of title is outstanding until a car is first sold at retail. Accordingly, any conflict between the secured party and the first retail purchaser of an automobile will usually be governed exclusively by the [Uniform Commercial] Code. 2 James J. White & Robert S. Summers, Uniform Commercial Code § 26-17 (3d ed. 1988) [hereinafter White & Summers ]. For instance, in Sterling Acceptance Co. v. Grimes, 194 Pa.Super. 503, 168 A.2d 600 (1961), the lender’s security interest had been noted on a special dealer’s certificate of title. Id., 168 A.2d at 601-02. The court held that the purchaser from the dealer was still a buyer in the ordinary course of business under U.C.C. § 9-307 and took free of the security interest, even though the secur 1989) (<HOLDING>). White and Summers also believe that the
holding that purchaser was buyer in the ordinary course despite fact that lender still held mso holding that purchaser of used car from dealer was buyer in ordinary course under sections 9307 and 2403 even though lender still held certificate of title holding that a purchaser may be a buyer in the ordinary course and defeat a security interest even if no insistence that the mso accompany delivery holding that a purchaser of a vehicle was a buyer in the ordinary course of business even though the car dealer did not provide the certificate of title at the time of the sale holding that with respect to owners summaryjudgment claims against subsequent buyers under ucc  24011 owners reservation of title in himself was limited in effect to reservation of security interest and that failure of owner to perfect his security interest made it subordinate under ucc  9  301lc to rights of buyer not in ordinary course of business