LexisNexis ( November 20, 2017, 1:58 PM EST) -- In our prior story, we reported on a recent Florida case where a governmental entity was held liable as an account debtor for double payment because it ignored a deflection notice sent by an assignee/factor of accounts receivable. UCC 9-406 was the critical UCC provision. Another recent Florida case applies the UCC 9-406 rules that the deflection notice passed muster under Article 9, but denied summary judgment in favor of the factor because waiver defenses raised issues of fact. Sometimes it seems like litigation comes in clusters....