"Taking" Co-Defendant's Advertising Idea Not Covered

Characterizing the action is limited to antitrust claims. The court in Suwannee Am. Cement LLC v. Zurich Ins. Co., Ltd., 885 F. Supp. 2d 611 (S.D.N.Y. 2012)determined that they did not implicate potential coverage, relying on the analysis of Rose Acre Farms, Inc. v. Columbia Cas. Co., 662 F.3d 765, 768-69 (7th Cir. (Ind.) 2011). In both instances, it was the co-defendants alleged advertising idea that was misused, and the court found that an impermissible basis for implicating that offense. That construction adds words of limitation not set forth in the policy and fails to focus on potential claims for false advertising asserted in both Rose Acre Farms and Suwannee, which neither court elected to address.