In Church E. Gates & Co., Inc. v. Empire City Racing Ass'n., 225 NY 142 (1919), it was held that a notice of lien setting forth a prior corporate name of the property owner was valid as a "change of name in no way affected the identity of the corporation", but a lien naming as owner a shareholder and officer of the corporation was invalid as this was not merely a "misdescription" of the true owner (pp. 155-156).