KANSAS CITY, Mo. - A majority of the Eighth Circuit U.S. Court of Appeals on July 24 affirmed that an insurer has no duty to defend its insured against an underlying complaint because the complaint did not allege facts that would indicate that the trademarked phrase "Nature's Own" has the potential to be a "title" or a "slogan" and because the record is insufficient to demonstrate what a reasonable investigation by the insurer would have revealed about the underlying claimants' use of the trademark (Interstate Bakeries Corporation v. OneBeacon Insurance Company, No. 11-1802, 8th Cir.; 2012 U.S. App. LEXIS 15200).