The Ninth Circuit, applying Oregon law, limited the scope of the insuring agreement for "damages because of 'bodily injury'" and found there was no duty to defend. Bliss Sequoia Ins. & Risk Advisors, Inc. v. Allied Prop. & Cas. Ins. Co., 2022 U.S. App. LEXIS 29905 (9th Cir. Oct. 27, 2022). 

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