PASADENA, Calif. - An underlying complaint's language is sufficient to potentially bring it within two policies' "advertising injury" coverage, which triggers an insurer's duty to defend, the Ninth Circuit U.S. Court of Appeals ruled June 18, reversing a lower court's grant of summary judgment in favor of an insurer on claims including bad faith (Tradewind Products Inc. d/b/a Youcansave.com v. Hartford Fire Ins. Co., Hartford Casualty In. Co., No. 07-55550, 9th Cir.; 2008 U.S. App. LEXIS 13153). From Mealey's Litigation Report: Insurance Bad Faith