LOS ANGELES - Finding that a property owner's claim against a subcontractor did not include allegations of property damage, a California appeals panel on May 16 held that a commercial general liability (CGL) insurer did not have any duty to defend the subcontractor, affirming that the insurer did not breach its contract or act in bad faith (Regional Steel Corp. v. Liberty Surplus Insurance Corp., No. B245961, Calif. App., 2nd Dist.; 2014 Cal. App. Unpub. LEXIS 3496).