Advertising Requires Widespread Promotional Activities

Hameid v. National Fire Ins. of Hartford, 31 Cal. 4th 16 (2003) (Amicus curiae for United Policyholders) (Limited scope of opinion by persuading Court to add the term "usually" to the definition of "advertising" which provides: "widespread promotional activities usually directed to the public at large" (id. at 24) and expand the scope of the definition to embrace "specific market segments" so that the definition of "advertising," where undefined in the policy, was not narrower than that subsequently adopted by the policy's drafter, ISO, in its next iteration of the policy. "We have limited our review to the question presented and do not have occasion to decide whether widespread promotional activities directed at specific market segments constitute advertising under the CGL policy." Id. at 24 n.3.).