Seventh Circuit Takes Broad View of Relatedness Under D&O ‘Claims Made’ Policies

Federal appeals court holds a complaint that originally has one declaratory-relief claim against one company and is amended to add damages claims against additional companies and directors constitutes a single claim for the purposes of a “claims made” D&O policy

The defendants were required to notify their insurer when the original complaint was filed

The concurring opinion observes that the decision gives policyholders a powerful incentive “to flood the D&O insurer with notice of even seemingly minor claims (even well within a policy deductible)”