SAN DIEGO - An insurer's denial of liability and a low-ball settlement offer to an individual allegedly injured by its insured do not constitute an effort to defraud, a state court held March 18 in affirming dismissal of California unfair competition law (UCL) claims (Emanuel McCray v. Metropolitan Transit System, et al., No. D060802, Calif. App., 4th Dist., Div. 1; 2013 Cal. App. Unpub. LEXIS 1943).