U.S. District Court for the Northern District of Illinois
In Maxum Indem. Co. v. Eclipse Mfg. Co., ___ F.Supp.2d ___, (N.D. Ill. June 13, 2011), the U.S. District Court for the Northern District of Illinois held that claims asserted in an underlying class action based on the federal Telephone Consumer Protection Act (TCPA) did not allege covered "property damage" caused by an unexpected or unintended "occurrence," and that any potential advertising injury coverage for the TCPA claims was limited to claims asserted by individuals who are not associated with a business entity.
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