The Scope of the Prior Publication Exclusion: Now You See It, Now You Don't

October 2005

In 1993 the Eastern District of Michigan ostensibly applied Florida law when determining whether an insurance policy's exclusion for prior publication applied to an advertising injury claim. The court's incomplete analysis of Florida law and "tortured reading" of the standard Insurance Services Office, Inc. (ISO), policy language has created confusion among courts and expanded coverage for advertising injury in ways never contemplated by insurers or policyholders.

by R. Steven Rawls and Rebecca Appelbaum
Butler Pappas Weihmuller Katz Craig, LLP

"Advertising injury," is typically defined as follows:

"Advertising injury" means injury arising out of one or more of the following offenses:

  1. Oral or written publication of material that slanders or libels a person or organization or disparages a person's or organization's goods, products or services;
  2. Oral or written publication of material that violates a person's right of privacy;
  3. Misappropriation of advertising ideas or style of doing business; or
  4. Infringement of copyright, title or slogan.

The prior publication exclusion (sometimes called the first publication exclusion) eliminates coverage for "advertising injury" "arising out of oral or written publication of material whose first publication took place before" the beginning of the policy period (or prior to the retroactive date, etc.).

Irons Home Builders: Exclusion Must Explicitly Refer to All Listed Coverages

In Irons Home Builders, Inc. v. Auto-Owners Insurance Co., 839 F. Supp. 1260 (E.D. Mich. 1993), the court considered the scope of the prior publication exclusion applicable to advertising injury coverage under Florida law. The insured, Irons Home Builders, was sued by a construction company alleging that Irons had copied a set of house plans and built three houses using the infringed plans. The parties settled for $17,500, resulting in a judgment against Irons that found that Irons had infringed the copyright by copying the plans and constructing the houses.

Irons notified Auto-Owners of the judgment and requested payment for both the judgment and the $34,779.91 incurred in defense costs. Auto Owners denied coverage, claiming that its policy was not triggered and, if so, the prior publication exclusion precluded coverage because the first instance of copyright infringement occurred before the policy covering such conduct came into effect. Irons filed suit for breach of contract and bad faith.

The Ruling

Auto Owners also argued that any later infringement was also not covered because it arose out of the original copying of the plans. The court found that the prior publication exclusion did not apply because the language of the exclusion explicitly stated that it applied to "oral or written publication of material." The court found this language tracked the coverage language for advertising injury involving libel, slander, and invasion of privacy. Consequently, the court reasoned that "the exclusion provision ... merely limits the coverage for advertising injury that arises from those three particular torts. [Emphasis supplied.] There is no exclusionary provision that limits coverage where one of several instances of copyright infringement occurred before the effective date of the policy." Irons at 1264–5.

The court cited Florida's general rule of interpreting insurance policies "strictly against [Auto Owners] and liberally in favor of Irons." Irons at 1265. The court went on to note that "[w]here the terms of an insurance contract are susceptible of two reasonable constructions, that interpretation which will sustain coverage for the insured will be adopted." Id. (citations omitted). The court concluded that "[g]iven the duplicate language of the provision, it is a reasonable construction of the provision that it only applies to libel, slander, and invasion of privacy, not to copyright infringement." Id.

In so doing, it appears that the Irons court failed to consider Florida's primary rule of policy construction: insurance contracts are construed according to their plain meaning and, in failing to do so, misconstrued the policy. See e.g., Swire Pacific Holdings, Inc. v. Zurich Ins. Co., 845 So. 2d 161, 165 (Fla. 2003). Moreover, Florida does not follow those jurisdictions that apply the doctrine of reasonable expectations. Deni Associates of Florida, Inc. v. State Farm Fire & Cas. Ins. Co., 711 So. 2d 1135, 1140 (Fla. 1998). Under Florida law, "only when a genuine inconsistency, uncertainty, or ambiguity in meaning remains after resort to the ordinary rules of construction" that the policy should be construed against the drafter/insurer. State Farm Mutual Auto. Ins. Co. v. Pridgen, 498 So. 2d 1245, 1248 (Fla. 1986). Courts cannot "rewrite contracts, add meaning that is not present, or otherwise reach results contrary to the intentions of the parties." Id.

Some courts have adopted the Irons reasoning that the prior publication exclusion does not apply in misappropriation or copyright infringement cases because the duplicate language appears only in subsections (a) and (b) of the advertising injury definitions. See, Westfield Cos. v. O.K.L. Can Line, 804 N.E.2d 45, 53 (Ohio App. 2003); Adolfo House Distrib. Corp. v. Travelers Prop. & Cas. Co., 165 F. Supp. 2d 1332, 1342 (S.D. Fla. 2001). Irons is also cited occasionally for the bootstrap proposition that the language must be ambiguous if reasonable circuit courts differ and, thus, the prior publication exclusion does not preclude coverage for and "advertising injury" which does not mimic the exclusionary language. See, Adolfo House at 1342; Cincinnati Ins. Cos. v. Pestco, Inc., 374 F. Supp. 2d 451, 461 (W.D. Pa. 2004).

Applied Bolting Technology Products: Exclusion Need Not Explicitly Refer to All Listed Coverages

The case to which the Irons progeny usually refers when asserting that ambiguity must be present is the differing result in Applied Bolting Technology Products, Inc. v. U.S. Fid. & Guar. Co., 942 F. Supp. 1029 (E.D. Pa. 1996). The Applied Bolting court applied Vermont law (and common sense) to determine that the prior publication exclusion applies to all of the enumerated definitions of "advertising injury."

Applied is also a copyright infringement case in which the court observed that "the exclusion must be read to give effect to the plain meaning of 'advertising injury.'" Applied at 1037. If the offending advertisement was made before the coverage period began, then the policy excluded coverage. The insured, Applied, made the Irons argument that, because the advertising injury at issue did not arise out of libel, slander, or invasion of privacy, the exclusion did not apply. The Applied court rejected this argument and explicitly disagreed with Irons. See also, Taco Bell Corp. v. Continental Cas. Co., 2003 WL 1475035, 7 (N.D. Ill March 17, 2003) (unequivocally rejecting Irons in favor of Applied); Tradesoft Technologies, Inc. v. Franklin Mut. Ins. Co., Inc., 746 A.2d 1078 (N.J. Super. 2000) (fully endorsing Applied).

In finding that the "first-publication exclusion applies to all of the offenses listed in the four-subpart definition of 'advertising injury,'" the Applied court reasoned:

  • "Advertising injury" is defined by the four, not two, offenses expressly set forth in the policy to define "advertising injury." ... I read this exclusion to mean that "advertising injury," which I must assume the insurance company intentionally surrounded with quotation marks when it used that term in the exclusion, has the same four-subpart meaning when used in the exclusion that it has every other time it appears in the policy surrounded by quotation marks. ... [I]t is certainly irrelevant that some of the language in the exclusion happens to match some of the words in subpart (a) and (b) of the definition of "advertising injury" but not match some of the language in (c) and (d).

Applied at 1037. The court further explained that the purpose of the exclusion was to avoid precisely the situation at issue: providing coverage for republication of an offending advertisement first published prior to the insured obtaining coverage.

Cases following Applied have found that the exclusion must be read to encompass all of the offenses contained in the definition of "advertising injury" and have expanded the Applied rationale. Tradesoft explained that to apply Irons "not only constitutes a tortured reading of the coverage" but is "contrary to the legal concepts involved." Tradesoft at 147–8.

Tradesoft reasoned that there can be no defamation, or invasion of privacy, without publication. However, infringement and misappropriation do not require publication as an element of the offense. "Our point is that the use of the term 'publication' in respect of defamation and invasion of privacy defines the offense and not the injury. The publication element of the injury is obviously common to all four categories of advertising injury, and the first-publication exclusion is, therefore, also common to all." Tradesoft at 148.

Similarly, the court in Matagorda Ventures, Inc. v. Travelers Lloyds Ins. Co., 208 F. Supp. 2d 687 (S.D. Tex. 2001), explained that "'advertising injury' can arise from misappropriation or infringement without the necessity of publication" whereas "advertising injury" arising from subparts (a) and (b) "is limited to that arising from publication of oral or written material." Matagorda at 689.

The injury at issue in Matagorda was misappropriation. The court, after quoting and endorsing Applied, explained that "[w]hen, as here, the alleged misappropriation arises from written published materials, the first publication exclusion applies. If the misappropriation or infringement does not arise from the publication of oral or written material, it would still fall within the Policy definition of 'advertising injury,' but the first publication exclusion would be irrelevant and inapplicable." Id.Matagorda also dismisses the ambiguity argument, explaining that "[a] split of authority among courts as to the interpretation of policy language does not necessarily make that language ambiguous." Id. at 690.

Conclusion

Courts that have considered the scope of the prior publication exclusion to advertising injury coverage for misappropriation and infringement have reached conflicting results. The Applied line of cases appears to provide the better reasoned analysis. That case and its progeny hold that the only reasonable interpretation of the prior publication exclusion applies the exclusion to all of the policy definitions of "advertising injury." As explained by Hugo Boss Fashions, Inc. v. Federal Ins. Co., 1999 WL 1072819, 1 (S.D.N.Y. Nov. 29, 1999) failure to apply the exclusion to all of the subparts of the "advertising injury" definition "would not only amount to an unreasonable interpretation of the policy, but would also amount to this Court impermissibly redrafting the contract in the plaintiffs' favor."


Contributing author Rebecca C. Appelbaum is an associate with Butler Pappas Weihmuller Katz Craig, LLP, practicing in the areas of third-party coverage and third-party liability defense.


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