As an update to our March 8, 2022 blog post discussing coverage for phishing scams in the context of Ernst & Haas Mgt. Co. v. Hiscox, Inc., 23 F.4th 1195 (9th Cir. 2022), a new Alaska case relied on Ernst & Haas to find coverage under a similar set of facts. See City of Unalaska v. Natl. Union Fire Ins. Co., 3:21-CV-00096-SLG, 2022 WL 826501, at *1 (D. Alaska Mar. 18, 2022).
Background: Different Insurer, Same Story
As a reminder, in Ernst & Haas, a property management company was defrauded…
