Conversely, Article 9 [Maine cite Article 9-A] will come into play only if the litigation arises in a UCC jurisdiction or if a foreign choice-of-law rule leads a foreign court to apply the law of a UCC jurisdiction. For example, if issues concerning a security interest granted by a foreign airline to a New York bank are litigated overseas, the court may be bound to apply the law of the debtor's jurisdiction and not New York's Article 9.

10. Certain Statutory and Common-Law Liens; Interests in Real Property. With few exceptions (nonconsensual agricultural liens being one), this Article applies only to consensual security interests in personal property. Following former Section 9- 104(b) and (j), paragraphs (1) and (11) of subsection (d) [Maine cite paragraphs (a) and (k) of subsection (4)] exclude landlord's liens and leases and most other interests in or liens on real property. These exclusions generally reiterate the limitations on coverage (i.e., "by contract," "in personal property and fixtures") made explicit in subsection (a)(1) [Maine cite subsection (1), paragraph (a)]. Similarly, most jurisdictions provide special liens to suppliers of many types of services and materials, either by statute or by common law. With the exception of agricultural liens, it is not necessary for this Article to provide general codification of this lien structure, which is determined in large part by local conditions and which is far removed from ordinary commercial financing. As under former Section 9-104(c), subsection (d)(2) [Maine cite subsection (4), paragraph (b)] excludes these suppliers' liens (other than agricultural liens) from this Article. However, Section 9-333 [Maine cite section 9-1333] provides a rule for determining priorities between certain possessory suppliers' liens and security interests covered by this Article.

11. Wage and Similar Claims. As under former Section 9- 104(d), subsection (d)(3) [Maine cite subsection (4), paragraph (c)] excludes assignments of claims for wages and the like from this Article. These assignments present important social issues