Ohio Rev. Code Ann. § 1307.503
Document of title to goods defeated in certain cases [UCC 7-503]
(A) A document of title confers no right in goods against a person that before issuance of the document had a legal interest or a perfected security interest in the goods and that did not:
(1) Deliver or entrust the goods or any document of title covering the goods to the bailor or the bailor's nominee with: