Late last year we discussed a recent New York Court of Appeals decision weighing the effect of certain indenture provisions on a purported strict foreclosure of collateral under the Uniform Commercial Code. See Goodstein, CNH Diversified (Marblegate 2.0) and Strict Foreclosure, 264 N.Y.L.J. 107 (Dec. 3, 2020)). In the CNH Diversified case, minority noteholders party to an indenture challenged a strict foreclosure, claiming that their consent was required under the terms of such indenture. That challenge was upheld by the Court of Appeals. More recently, the New York State Supreme Court Appellate Division, First Department, issued a ruling in yet another case challenging a UCC strict foreclosure. In this instance, the challenge to the foreclosure action was not sustained. In both cases, the parties had complied with the procedural requirements for strict foreclosure actions under Article 9 of the UCC.