Directors and Officers policies are typically claims-made policies which attempt to exclude coverage for wrongful acts which occur after the inception of the policy but arise from a nucleus of facts which preceded the inception of the policy. As a result, questions as to whether later acts are “interrelated” with prior acts can be tremendously important. A recent decision by the United States District Court for the Central District of California, XL Specialty Insurance Co. v. Michael Perry, June 27, 2012, granted summary judgment to insurers on interrelatedness grounds and provides an interesting discussion of the issue.