Settlement Uncovered Where Christmas Lights Promoted in Showroom Displays and Selected Customer Presentations
Santa’s Best Craft, LLC v. Zurich Am. Ins. Co., 941 N.E.2d 291, 304-05 (Ill. App. Ct. (1st Dist., 2d Div.) 2010) The court’s decision requiring “actual coverage” only comports with earlier precedent if potential coverage of the claim asserted was found not to be a “primary focus” at the time of settlement. But under Zurich’s…