On January 15, L obtained a $50,000 judgment against D Company. On February 2, S loaned D Company $25,000 to buy a computer server. D Company purchased the server using the loan proceeds that same day, and granted S a valid security interest in it.

On February 5, L tried to collect his $50,000 judgment against D Company by having the sheriff levy on D Company's server.

S filed a financing statement covering the server on February 17. Which statement correctly describes who has priority in the server as between L and S?

1. S, because a security interest always has priority over a lien creditor

2. S, because S filed its financing statement within 20 days after D Company took possession of the server

3. L, because the rights of a lien creditor take priority over a security interest

4. L, because S's security interest was unperfected at the time of the sheriff levied on the server