TCPA Claims Not Covered as Violation of Right to Privacy Under Personal Injury Provision Where There Is No Publication To Third Parties

In Yahoo! Inc. v. National Union Fire Insurance Company of Pittsburgh, PA (June 2, 2017) 2017 WL 2405025, the District Court for the Northern District of California addressed the scope of coverage for lawsuits alleging violation of the Telephone Consumer Protection Act, 47 U.S.C. § 227 (“TCPA”), under personal and advertising injury coverage for “oral or written publication, in any manner, of material that violates a person’s right of privacy” contained in a Commercial General Liability policy.

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