Others define related claims as claims involving the same or related facts . . ., or interrelated wrongful acts as any causally connected Wrongful Act or series of the same, similar, or related Wrongful Acts. The exact policy language is critical. Courts have come to differing conclusions about whether the above formulations are plain or ambiguous, and about exactly what the language means in practice. Next, check the Limits of Liability section of the policy. There should be a provision stating that all related claims (or claims alleging interrelated wrongful acts) are treated as one claim that was made at the time of the first such claim, similar to the following: All Related Claims shall be deemed a single Claim and such Claim shall be considered first made on the date the earliest such Related Claim is first made against an Insured, regardless of whether such date is before or during the Policy Period. Interpreting the Policy Courts often cite dictionary definitions to interpret insurance policy language. Many courts have found that a common nexus unambiguously means what Merriam-Websters dictionary says it means: a relationship or connection between people or things, and a connection, link; The Most Recent News Concerning Claims Adjusters also: a causal link; a connected group or series; center, focus. Such courts often find that the language requires a focus on similarities, not differences, among claims, and that claims have enough in common when they involve the same underlying circumstances. Other courts have focused on the word any in these definitions to find that the definition is very broad. What does this mean in practice? Because the determination of whether claims are related (regardless of whether or how that is defined) is a very fact-specific inquiry, the cases are all over the map. This may make it hard to find a case precisely on point from a factual perspective.

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