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Audit Bureau of Circulations v. Axis Specialty Insurance Company

2009 WL 2765716 (N.D. Ill. 2009)

Words & Phrases

Duty To Defend: Intentional Act

Trial Judge



Insurer had no duty to defend complaint that alleged intentional acts because possibility of additional theories of recovery was not the equivalent of “true but unpleaded facts,” which trigger a duty to defend.