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Lien Creditor”.As was true under former Article 9, under new section 9-102(a)(52) a “lien creditor ” is a creditor who obtains a lien by litigation, especially through execution.  As noted in Chapter 3 (The Nature of Secured Credit under Article 9), the most common lien making a person a lien creditor is a lien arising by a levy pursuant to a writ of execution.