Comsat Corporation v. St. Paul Mercury Insurance Co., No. 97-2236, 1998 WL 34088218 (D. Minn. March 6, 1998)

The court found a duty to defend arose for claims asserted in an antitrust lawsuit within St. Paul's 1986 ISO style coverage for "making known to any person or organization written or spoken material that belittles the products, work, or the completed work of others." The fact allegations of disparagement were asserted in interference claims. The court reasoned, "If sufficient facts were pled in Sea-Fone that would support a covered ‘claim' or ‘offense', then the duty to defend is implicated, even though the Amended Complaint did not allege a specific count or theory of liability which fit neatly into one of the enumerated offenses in the St. Paul policy. . . . [I]n many cases interference with contract is not so much a theory of liability in itself as it is an element of damages resulting from the commission of some other tort."