LOS ANGELES - An insurance broker breached an oral or implied contract by failing to use reasonable efforts to procure insurance with theft coverage, a California appeals panel affirmed Oct. 9 (Online Carstereo.com v. Behrooz Meimand Insurance Services Inc., No. B243365, Calif. App., 2nd Dist., Div. 2; 2013 Cal. App. Unpub. LEXIS 7259).