Post-Lawsuit Inception Conduct Potentially Covered

Superformance International Inc. v. Hartford Cas. Ins. Co., 332 F. 3d 215, 219 (4th Cir. (Va.) 2003). ("Because we cannot come as law, foreclose the possibility that count 7 of the Shelby complaint, in the entire Ford complaint [which were added to the Mass. Litigation after Superformance secured the insurance policy] allege some conduct occurring during the policy period, we agree that coverage for these counts cannot categorically be borne by invocation of the policy period, i.e., March 9, 2001 to March 9, 2002. Accordingly, with respect to those counts - Count 7 of the Shelby Complaint and the 6 Counts of the Ford Complaint, we turn to the language of the policy to determine whether it affords a defense to Superformance.")