A California appellate court ruled an email exchange did not constitute a claim under an insured's claims-made CGL policy. The case is Playboy Enters. v. Indian Harbor Ins. Co., 2022 Cal. App. Unpub. LEXIS 6027 (Cal. Ct. App. 2022). Please note that this case has been designated "not to be published in official reports" and is therefore not citable. 

The Underlying Case 

Elliott Friedman had two contracts with Playboy to sell licensed, Playboy-branded products in Asia, but both deals failed before they were finalized. Friedman complained it had been the self-dealing behavior of Playboy executives that ultimately sank the deal. In the spring of 2016, Friedman emailed Playboy's general counsel and said he "would rather focus…on settling the issues and just getting compensated for [his] investment." Friedman requested a meeting with Playboy's general counsel to discuss the matter. The meeting did not resolve the conflict, and Friedman sued Playboy over the failed business deal.