PHILADELPHIA - Granting commercial general liability insurers' motion for summary judgment in a breach of contract lawsuit, a Pennsylvania federal judge held Aug. 31 that underlying construction defects claims against insureds fail to amount to an "occurrence" under the policies and that the "real estate development activities-completed operations" exclusion further bars coverage (Northridge Village LP, et al. v. Travelers Indemnity Co. of Connecticut, et al., No. 15-1947, E.D. Pa., 2017 U.S. Dist. LEXIS 140541).