Travelers Prop. Cas. Co. of Am. v. Charlotte Russe Holding, Inc., No. B232771, 2012 WL 2356477 (Cal. App. (2 Dist.) June 21, 2012)

Pursuant to Gauntlett & Associates' Request for Publication on July 11, 2012, the Court of Appeal published Charlotte Russe on July 13, 2012.

The Court of Appeal held that a manufacturer's allegations of price discounts "may" result in a loss that "might" be covered under the "personal injury" coverage provided under a Commercial General Liability policy. Charlotte Russe's promotion of the claimant's jeans, which from the claimant's perspective was "highly discounted," implicitly disparaged its brand and products. The court clarified that not all elements of implicit disparagement need be alleged in order to establish potential coverage.