CHICAGO - The Seventh Circuit U.S. Court of Appeals on May 23 held that a trade dress claim was not the primary focus of an underlying $3.5 million settlement, affirming a lower court's finding that an insured is not entitled to an award for settlement reimbursement and prejudgment interest from its insurer (Santa's Best Craft LLC, et al. v. St. Paul Fire and Marine Insurance Company, No. 11-2115, 7th Cir.; 2012 U.S. App. LEXIS 10356).