In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Example Input: of the debtor. This distinction appears immaterial under the language of sec. 409.402(7), Stats. 7 In other contexts, a security interest properly perfected at one time may later become unperfected through creditor inaction. See, e.g. sec. 409.103(l)(d)l, (2)(b), (3)(e), Stats, (four month grace periods preserving perfection in collateral removed from jurisdic tion); sec. 409.403(2) (lapse of financing statements after 5 years unless continued). 8 Interestingly, the Ansley court held that a filing under "the name Ansley Farms instead of the debtor's true name — Emory Ansley — is seriously misleading, making [the]. . . security interest unperfected.. . ." Id,., 467 F.Supp. at 55. Other cases reaching similar results are In Re Wishart, 10 U.C.C. Rep. Serv. 1296 (Bankr.W.D. Mich. 1972) (<HOLDING>); In Re Brawn, 7 U.C.C. Rep. Serv. 565 (D.C. 
 Holding statements: (A) holding that the filing of notice without motion is insufficient (B) holding a filing under mccauleys reprographics and mapping insufficient to perfect a security interest in the assets of the debtor corporation (C) holding that the reservation of a claim need not name a defendant but only identify the type of claim the debtor seeks to retain (D) holding a filing under wishart equipment co insufficient to identify the debtor horace wishart (E) holding a filing under john and mayella lintz insufficient to identify the debtor corporation
Example Output: holding that the filing of notice without motion is insufficient

Example Input: v. Libbey-Owens-Ford Glass Co., 376 F.2d 711 (7th Cir. 1967), stated that section 2(d) shows that the legislature contemplated multiplicity of actions and provides a court with two options: stay the entire proceeding pending arbitration, or, if the issue is severable, the stay may be granted with respect to that issue only. 710 ILCS 5/2(d) (West 1994). The Galt court explained: “In enacting the Uniform Arbitration Act, the [Illinois] Legislature has not eradicated a chancellor’s inherent powers, but the legislature has determined in Section 2 that it is no longer equitable to enjoin arbitration to prevent multiplicity of actions.” Galt, 376 F.2d at 716. See Moses H. Cone Memorial Hospital v. Mercury Construction Corp., 460 U.S. 1, 20, 74 L. Ed. 2d 765, 782, 103 S. Ct. 927, 939 (1983) (<HOLDING>). Accord Dean Witter Reynolds Inc. v. Byrd, 470 
 Holding statements: (A) holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs (B) holding that once the party seeking to compel arbitration establishes the existence of an arbitration agreement and that the claims raised fall within the scope of that agreement the trial court must compel arbitration (C) holding that the federal arbitration act requires piecemeal resolution when necessary to give effect to an arbitration agreement and mandates enforcement of an arbitration agreement notwithstanding the presence of other persons who are parties to the underlying dispute but not to the arbitration agreement emphasis added (D) holding that an arbitration agreement is separable from the underlying agreement (E) holding that the faa mandates courts to direct parties to arbitration on issues to which a valid arbitration agreement has been signed
Example Output: holding that where an arbitration agreement between an employer and employee does not specifically provide for the handling of arbitration costs california courts should interpret the arbitration agreement  as providing  that the employer must bear the arbitration forum costs

Example Input: 1999, she did receive that review in November, after Compuware took measures to correct the lapse. Although the review noted several performance deficiencies, Compuware nonetheless awarded Ms. Thomas a 4% increase, made retroactive to September when the salary review should have been completed. And, although Ms. Thomas complains that the amount of the salary increase was less than other employees received, she has presented no evidence that the increase was outside the range for which she was eligible. Neither a late but retroactive pay raise, nor a pay raise within the applicable range but less than the employee subjectively believes she deserved, constitutes a “materially adverse employment action.” See Kocsis v. Multi-Care Management, Inc., 97 F.3d 876, 886-87 (6th Cir.1996) (<HOLDING>). We note, for the record, that in White v. 
 Holding statements: (A) holding that a lateral transfer without a loss in benefits does not constitute an adverse employment action (B) holding that termination is an adverse employment action (C) holding that a materially adverse action is of the magnitude of a termination of employment or a decrease in salary or a material loss in benefits (D) holding that in order to constitute a materially adverse change in the terms of plaintiffs employment a transfer must include either diminished responsibilities a demotion evidenced by a change in salary title or benefits or other indices unique to the particular situation (E) holding that a negative criticism or performance evaluation unaccompanied by a materially adverse change in the terms or conditions of employment does not constitute adverse employment action
Example Output:
holding that a lateral transfer without a loss in benefits does not constitute an adverse employment action