While the Arizona Appellate Court found limited coverage for a computer fraud attack against the insured, it also determined there were multiple occurrences. AIMS Ins. Program Managers, Inc. v. Nat'l Fire Ins. Co., 2921 Ariz. App. Unpub. LEXIS 123 (Ariz. Ct. App. Feb. 4, 2021).

    Thieves secretly accessed from an

    The policy's false pretense exclusion relied upon the insurer to deny coverage for an act of cyber fraud was found ambiguous. Rainforest Chocolate v. Sentinel Ins. Co., 2018 VT LEXIS 140 (Vt. Dec. 28, 2018).

    Rainforest Chocolate, LLC was insured under a business-owner policy issued by Sentinel. In May 2016