Hameid v. National Fire Insurance of Hartford

We granted review to determine a limited issue: When a plaintiff alleges in an underlying complaint that an insured defendant took a competitor's customer list and solicited customers from it, was the defendant's act a misappropriation of advertising ideas that gave rise to the insurer's duty to defend defendant under the ""advertising injury"" provision of the commercial general liability (CGL) insurance policy? (On May 15, 2002, we filed the order specifically limiting the issue on review to coverage under the advertising injury provision.) We conclude the term ""advertising injury"" as used in the CGL policy requires widespread promotion to the public such that one-on-one solicitation of a few customers does not give rise to the insurer's duty to defend the underlying lawsuit. For this reason, we reverse the Court of Appeal judgment, which concluded the allegations satisfied the ""advertising injury"" provision of the CGL insurance policy. FACTS