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: that post-1978 refinancing of a debt did not constitute a novation, thus debtor could not avoid liens on equipment it owned prior to the 1978 enactment of the Bankruptcy Code where no new money was advanced, no additional security was encumbered, and varying the term of years and interest rates was done to benefit the debtor); In re Hemingson, 84 B.R. 604 (Bankr.D.Minn.1988) (<HOLDING>); Geist v. Converse County Bank (In re Geist),
Holding statements: (A) holding that in georgia pursuant to 9107 of the ucc refinancing of a promissory note transforms the obligation thereby destroying purchase money nature of the security interest therefore the creditor lost its purchase money security interest pmsi in a television set when the loans were consolidated and lien was avoidable id 89 br 264 18 bcd 58 (B) holding that there was no presumption of a gift where the wifes money was used to make the purchase but title was placed in the name of the husband and finding the facts sufficient to establish a purchase money resulting trust in favor of the wife (C) holding that under minnesota law refinancing and consolidation of purchase money loans did not destroy their purchase money character for bankruptcy lien avoidance purposes (D) holding that a purchase money security in jewelry was not lost when the perfected purchase money security interest was consolidated with a subsequent retail installment contract (E) holding section 501 applies to both purchase money and refinancing mortgages
Example Output: holding that in georgia pursuant to 9107 of the ucc refinancing of a promissory note transforms the obligation thereby destroying purchase money nature of the security interest therefore the creditor lost its purchase money security interest pmsi in a television set when the loans were consolidated and lien was avoidable id 89 br 264 18 bcd 58

Example Input: aff'd, 683 So.2d 1042 (Ala.1996), cert. denied, 520 U.S. 1171, 117 S.Ct. 1438, 137 L.Ed.2d 545 (1997), quoting Ex parte Wilson, 571 So.2d 1251, 1261 (Ala.1990). In Brooks v. State, 695 So.2d 176 (Ala.Cr.App.1996), aff'd, 695 So.2d 184 (Ala.), cert. denied, 522 U.S. 893, 118 S.Ct. 233, 139 L.Ed.2d 164 (1997), this Court stated: "[A] prosecutor has the right to indicate to the jury those parts of the evidence or testimony presented by the State that the defense has failed to contradict; that process is not an infringement of the defendant's Fifth Amendment privilege against self-incrimination. Duncan v. Stynchcombe, 704 F.2d 1213, 1215-16 (11th Cir.1983); Ex parte McWilliams, 640 So.2d 1015 (Ala.1993); Griffin v. State, 393 So.2d 523, 528 (Ala.Cr.App.1981)." 695 So.2d at 180 (<HOLDING>). " ' "A prosecutor's statement that the
Holding statements: (A) holding that it was permissible for prosecutor to comment on the general failure of the defense to produce any evidence (B) recognizing the right of a defendant to comment upon the failure of the state to produce evidence (C) holding that comment by prosecutor in closing argument that defense counsel did not produce evidence of the defendants innocence was not a comment on the defendants failure to testify (D) holding the prosecutors statements were not an inappropriate comment on the defendants failure to testify but rather a comment on the defendants failure to present convincing evidence to support his defense (E) holding a prosecutor may not comment on a defendants silence
Example Output: holding that it was permissible for prosecutor to comment on the general failure of the defense to produce any evidence

Example Input: court jurisdiction and its silence on the matter of federal jurisdiction"); Erienet, Inc. v. Velocity Net, Inc., 156 F.3d 513 (3d Cir.1998) (accepting the holding oi International Science, supra, that the federal statute "intended to authorize private causes of action only in state court"); Foxhall Realty Law Offices, Inc. v. Telecommunications Premium Services, Ltd., 156 F.3d 432, 438 (2d Cir.1998) ("Congress intended to confer exclusive state court jurisdiction over private rights of action" under the Act); Nicholson v. Hooters of Augusta, Inc., 136 F.3d 1287, 1289, modified 140 F.3d 898 (11th Cir.1998) ("Congress intended to assign the private right of action [under the Act] to state courts exclusively"); Chair King, Inc. v. Houston Cellular Corp., 131 F.3d 507, 510 (5th Cir.1997) (<HOLDING>). 6 . An earlier Texas intermediate appellate
Holding statements: (A) holding that there was no federal subject matter jurisdiction under the private cause of action provision of the act (B) holding there is no federal private right of action for borrowers under the nfia (C) holding veilpiercing claim does not state cause of action under erisa and cannot independently support federal subject matter jurisdiction (D) holding subject matter jurisdiction divested because federal cause of action had been dismissed without prejudice (E) holding that the elements of a cause of action were not subject matter jurisdictional simply because the statute that created the cause of action provided that district courts shall have jurisdiction of such actions
Example Output:
holding there is no federal private right of action for borrowers under the nfia