ATGF News and Blog

All the latest from ATGF

Good news! We found a way to help you save money!

posted May 18, 2018, 11:20 AM by Kim Whitlock   [ updated May 18, 2018, 11:37 AM ]

    In an ongoing effort to continually support our agents, ATGF has recently partnered with a third-party vendor, Ship Club, to provide discounted shipping rates to our agents in all states. This would allow our agents to take advantage of special group pricing for UPS, FedEx and USPS. While this is geared mainly toward agents who don’t currently have accounts with these shipping providers or another third-party vendor, if you already have an existing UPS, FedEx or third-party account, they can provide helpful tips and guidance on negotiating a better rate with your current shipping vendor.

    The payment option for shipping will be Net-15 via credit card, and they are developing an ACH option, which will be available in the coming months. Their shipping portal is very user friendly and you will have the option to choose from FedEx, UPS or USPS, whichever has the best pricing. You will be able to view and download your invoices online, and you’ll be able to order free supplies for the shippers you use.

    If you are interested in receiving more information and/or signing up for these special, discounted rates, please complete the attached questionnaire and email to Sharon Lynn is our point of contact and will setup your account through the website.

    If you have any other questions regarding this benefit, please contact Beth Starbuck via email at, or via phone at 303.383.4325.

ATGF Strengthens Leadership Team by Promoting Brian Phillips to CEO

posted May 8, 2018, 8:50 AM by Kim Whitlock

Denver, Colorado                                                                                                          May 7, 2018

Attorneys Title Guaranty Fund, Inc. (ATGF) Chairman, Maurizio Romanin, and President, Eric Morgan, announce that Brian Phillips has been named Chief Executive Officer of ATGF.  “We’re moving into an ambitious growth phase and adding strength to our senior leadership team.  Brian’s expertise and background make him a natural fit to lead operations and engage in ongoing development of our innovative technology for title agents,” Romanin stated.   

Eric Morgan will continue as President and have primary responsibility for ATGF’s licensing expansion, financial operations and regulatory relations.  “Expanding our leadership team allows us to devote greater resources to proactive business development initiatives.  Moving Brian into this role is a significant step for taking the company to the next level,” Morgan added. “I’m excited to focus on the areas where I can make the greatest contribution to our ongoing success.”

Phillips expressed his excitement at assuming this leadership role at a dynamic and growing company.  “ATGF’s record financial performance and dynamic, forward thinking approach have us in a great position to grow.  I look forward to building upon the success achieved since the Company’s transfer of ownership and management in 2010.  I’m excited to work with the exceptional employees at ATGF and to help our team continue delivery of exceptional support services to existing and new agents in many additional states.”

Mr. Phillips’s experience includes representing clients in land use disputes, title claims, defense of title insurers, as well as real estate acquisitions, development and finance.  He has a proven track record in assisting clients and achieving desired results.  Prior to joining ATGF, Mr. Phillips was Vice President and Senior Claims Counsel for a major national title insurer.   “After Phillips joined ATGF as Associate General Counsel early in 2017 I quickly recognized he was capable of leading ATGF’s next phase of growth,” said Romanin.  “Brian’s become an invaluable resource to our agents and our business,” added Morgan.  “We want to tap into all of his skills to grow our business and technological capabilities.” 

About Attorneys Title Guaranty Fund, Inc.

Founded in 1960, ATGF has been providing best in class title insurance underwriting and services for more than 50 years.  The company’s mission is helping agents succeed through trusted products and services, innovative technology and amazing support. ATGF has maintained a strong Financial Stability Rating® (FSR) of A, Exceptional, from the independent rating agency, Demotech, Inc. For more information on ATGF or EPIC, contact ATGF’s CEO, Brian Phillips at or 303-383-4333.

Auto-fill document date and notary acknowledgment info. in EPIC

posted May 7, 2018, 3:04 PM by Kim Whitlock

Your Closing / Signing date and Notary Acknowledgment information can be entered in the DOCUMENT CONTROL ITEMS tab. Anything entered here will populate into your Closing Package.



Should You Outsource?

posted May 7, 2018, 9:28 AM by Kim Whitlock

There are many ways to manage the ups and downs of the market. One option to consider is to create a variable cost structure to your business by outsourcing certain tasks.

There are hordes of outsource/BPO firms – all of whom extol their virtues openly. How do you know which ones are good? Most of them talk a good game and tell you what you want to hear. How do you know they aren’t learning title on your dime? How do you know they will deliver? Do they have adequate security policies and procedures in place to protect NPI, including personnel background checks sufficient to comply with US lender standards? What is the best way to manage them? What tasks should you start with?

ProsperitasForward is fortunate in that we really do get to see it all. We know the real-life experiences our clients have had with various vendors, and what an agency can truly expect. We can eliminate the guesswork.

Outsourcing can make a lot of sense if done right.

We typically see our clients identify non consumer facing tasks as ideal for an outsourcing plan. Those tasks include:

  1. Order Entry
  2. Closing Protection Letter Generation
  3. Commitment Typing
  4. Payoff Ordering
  5. HOA Document Processing
  6. Subordination Processing
  7. CD Preparation (with title, settlement and recording fees only)
  8. Policy Typing
  9. Cover Record Processing
  10. Post Closing File Audit

Aside the value of enabling a variable cost structure, outsourcing can save you money, improve efficiency, and provide better and faster deliverables so that you can focus on core services. Outsourcing can help level the playing field and give you access to the same economies of scale, efficiency, and expertise that the biggest title companies enjoy.

Done right, it can be a game changer.

– Howard Turk


Tips On How To Improve Your Team's Workflow Part II

posted May 7, 2018, 8:52 AM by Kim Whitlock   [ updated May 8, 2018, 8:48 AM ]


• Process improvement is ever evolving and in order to ensure you are the most successful at it you must constantly be looking for ways to make it better.
  • As new people come into the team or new tasks and deliverables are realized then team workflow must change.
  • Technology can also be a driving force behind changing or updating your workflow.
• Where are the biggest bottlenecks?
  •  Sometimes it’s not that you don’t have a process but rather that the process isn’t actually helping. It could actually be hurting the team’s workflow.
  •  When you setup your workflow you need to make sure that each part of the process makes sense and can be done the most efficiently so the next step can be done.
Example: Commitments aren’t getting completed on time.
• First thing you must do is ask why?
• There is a reason that you are not able to achieve this goal and you have to find out why?
• You might find that it could be caused by who is doing a certain process and in what order.
• Tasking one person with too many priorities can sometimes cause bottle necks.
  •  Order entry is done by the same resource that does Front desk/reception.
  •  Set guidelines for what gets done when and what takes priorities.
  •  Assigning one person with too many tasks means at some point something is going to give.
How to Resolve the Issue:
• Do you have enough people working on a stage of the process? Not enough resources will create a bottleneck.
• Are you using the most efficient method?
• If you don’t want to add more people then find out how less people can get more done.
• Top Watch It: Observe the work and time it. How many minutes does it take to process title and entering commitment data? Multiply that by how many there is to do on average and you will see if they can get it done in time.
• Pay attention to steps and tasks (opportunity to improve some or all steps in the process)

Stop the Chaos Before it Starts
• If you know problem spots, address them now.
• Develop processes to streamline workflow.
• Closings are hectic and many components come together at the last minute. Minimize the chaos and avoid last minute scrambling around.

Answer questions before they are asked
• Why wait to react when you can be proactive?
• Poll your teams and identify if there are questions that always get asked.
• Create job aids and resources to deal with common questions. Internal resource sharing goes
a long way.

Set a Service Level Agreement (SLA) with Your Partners
• Don’t wait on Your Partners.
• Set expectations upfront to key vendors and service providers to get you what you need
in a your timeframe.
• Knowing how long you may have to wait will allow users to work on other things and not
just play a waiting game.

Go Paperless
• We live in a world of paper. Ever add uphow much time you and your team spend
tracking down and sorting through all that paper?
• Having an effective paperless file management system will save you time and money.
• Use your TECHNOLOGY. Search and track documents electronically gets you what you
need much faster.
• Provides better audit

Cross Train Employees
• We have all been there... It’s the end of the month and your top closer is out sick!No one
knows anything about their files or even their job processes.
• Always have at least one other person in your office that can pick up someone’s work for
a day
• Have mechanisms in place where one can see easily what the other has to work on and
jump in.

• Rekeying and doing manual work just because it’s what you have always done equals a bad
• Take the time to learn what you have available to you within your software. Figure out how
you can work it into your team’s processes.
• Train, Enforce and validate the technologies you are leveraging to ensure for the highest level
of productivity.

Make a list the most boring and repetitive tasks. The tasks they are slowest at doing and complain the
most about are usually the tasks that tools solve best.

• Leverage a task management system. Every file should have a standard frame work of
tasks and workflow that you can plot out using your software.
• Leverage every integration you can find! Don’t rekey data that you can automate. It’s
quicker and leaves less room for error.
• Find technologies that help you communicate both internally andwith your customers.
• There are lots of interoffice chat tools that help users get out of the email habit. Email
can be a huge workflow killer if not used appropriately.
• If email is a must, create distribution lists. Ensure the right people and the right teams are
receiving the email rather than one individual where it may get lost.
• Utilize integrations for external communications.


posted Apr 10, 2018, 8:07 AM by Kim Whitlock

In order to insure EPIC continues to run smoothly we suggest the following

  •          Periodically delete cookies by select GENERAL TAB select SETTINGS, VIEW FILES, CTRL A to select all, then DELETE BUTTON from keyboard. Select YES to delete all and exit all windows. Then select F5 ON your keyboard to refresh changes.
  •          Select the hammer icon from your EPIC login screen. Once selected RUN file.
  •          Select the check mark icon from your EPIC login screen and follow the instructions above.


EPIC is web based and following these tips will insure all new utilities and updates have been installed.


posted Apr 9, 2018, 11:07 AM by Kim Whitlock   [ updated Apr 9, 2018, 11:08 AM ]

Why you need a workflow?

                     Keeps everyone on the same page, preventing miscommunication, confusion, and frustration about what other team members are doing.

                     Make the best use of time by eliminating bottlenecks.

o   68% of employees waste time waiting for information from team members, wasting an average of 3.5 hours a week.

                     Streamline reoccurring tasks. Try to find a way to automate it.

                     Workflow can help a team move forward.  Provides a trail of everything that occurred.

                     Having a workflow in place, NO MATTER HOW SIMPLE, brings so much sanity to a team.

                     When there’s a defined system in place, everyone knows exactly what their responsibilities are and how it will contribute to the bigger picture.

                     Everyone knows what’s expected of them and when, they know who to ask if they have a question.

How to get started

                     If you don’t already have a workflow you need to evaluate your need for one.

                     Even a one person show needs one. Your individual workflow is important; not having one likely means working less efficiently on certain things.

                     If you have teams that work together to complete common processes or tasks, then workflow is critical.      More people can cause more inefficiencies.

Never evaluated your workflow?  Rule     #1….keep it simple!!!

                     Don’t make it more trouble than it’s worth.

                     How to evaluate

o   Take a step back and think about how you or your team gets stuff done. Don’t overcomplicate things.

o   A quick brainstorming session on process and workflow on paper can get you the process map you need.

Improve Your Workflow

                     Now that you have documented your current workflow it’s time to tweak it to make it more efficient. As you do this keep these basic points in mind.

                     Make sure everyone is aware and accountable

                     Does everyone on the team feel empowered to contribute? When a workflow is determined everyone should understand the large mission of the organization and their role in making it successful.

                     Clearly identify and document each task and the role individual team members will play in order to make your workflow successful.

                     How you want to communicate?

                     We live in a world of distractions creating a need for clear communication.

                     Create guidelines for communicating both internally among team members and externally with partners and customers.

                     Example of an internal communication process:

o   If it’s urgent, ping them in an interoffice communication tool (such as Skype for Business)

o   If it’s not urgent, send an email – be short and brief

o   If it’s complicated, talk on the phone, Skype, or in person. (NO EMAIL)

With a clear process in place team members won’t have to continuously check email. Long email chains are inefficient and are often hard to follow.

·         Centralize your employee resources

o   Identify a place where all of your team’s information can live.

o   Make sure everyone knows where to find the information. It’s no good if no one can find it.

o   Prevents repetitive questions

·         Make key decisions about responsibility and expectations

o   Defining Roles

§  Who is responsible for what? Simple concept, yes, but many roles are vague and no one really knows who should be doing what.

§  Result of undefined roles? A lot of wasted time and overlap.

§  Make sure that each role fits as far as what they do and what they are accountable for. Be clear on deliverables.

o   Defining Deliverables

§  What is it and when is it due?  Not just what is the task, but what is the thing that results from the task?


For example, a  tasks might be: review title work. But the deliverable is: deliver title commitment.


§  A task always has a response.    The deliverable. The tangible result from the work.  The deliverable should have a due date as well, or else you’ll just spend all of your time reviewing title work and never getting any commitments done.

o   Setting Expectations

§  What does done mean?  What does completed, delivered mean?

·         Make sure everyone is on the same page with completing  tasks and deliverables so you don’t spend precious time going back and cleaning things up after the fact.

§  Take some time to figure out what kind of system works for you.

§  Keep tabs on if the system is working. Once a month or so check in with the team to make sure all is going smoothly.

§  Make adjustments.

§  Keep at it until you get the results you want

ATGF Reports Record Profits for Second Straight Year

posted Mar 21, 2018, 6:26 AM by Kim Whitlock

Attorneys Title Guaranty Fund, Inc. (ATGF) President Eric Morgan is pleased to announce a record net profit for 2017 of $726,016. This tops the previous high of $553,870 set in 2016.

“Since new ownership and management assumed control of ATGF in 2010-2011, we’ve completely transformed the culture and financial results of our company.  ATGF staff and ownership have really done a tremendous job of turning this company into an industry leader in technology and compliance,” Morgan stated.  “We’ve greatly expanded the company’s financial resources, including doubling the company’s surplus as regards policyholders in the past five years.”

The company’s proprietary web-based title production and underwriting system (EPIC) is a key factor in the company’s results. “Orders processed in EPIC continue to result in dramatically reduced claims versus business that was done prior to full implementation of the system.” ATGF provides the system to all its agents free of charge.

Morgan attributed the increased revenue to the quality of work performed by its nearly 400 independent agents, higher residential values, and achieving full underwriting authority in Minnesota and North Dakota. “We operated as a managing agent in Minnesota and North Dakota for many years, but in  2017 we are seeing the full effect of underwriting authority in those states on our bottom line. This puts us in a great position to pursue substantial geographical expansion in 2018 and are looking forward to supporting more independent title agents across the country.” Morgan added.

About Attorneys Title Guaranty Fund, Inc.

Founded in 1960, ATGF has been providing best in class title insurance underwriting and services for more than 50 years.  The company’s mission is helping agents succeed through trusted products and services, innovative technology and amazing support.  The company currently pursues this mission by underwriting, training and supporting agents in Colorado, Utah, Minnesota and North Dakota.  ATGF has maintained a strong Financial Stability Rating® (FSR) of A, Exceptional, from the independent rating agency, Demotech, Inc. For more information on ATGF or EPIC, contact ATGF’s president, Eric Morgan at or 303-383-4321.

11 First Sentences That Guarantee the Rest of Your Email Won't Get Read

posted Mar 13, 2018, 10:01 AM by Kim Whitlock

Even if your intentions are professional and sincere.

Imagine you get this email. You don't know the sender, but you open it anyway. How long would you keep reading?

Dear Jeff,

I hope you're having a great President's Day! I definitely am. Even though I'm spending a little time at work right now, I plan to spend at least part of the day having fun with friends. We're going snowboarding. I can't wait!"

"I am writing to ask if you would be interested in...

Would you keep reading? Generally speaking, would you even have made it to the second paragraph? I know: The sender was trying to establish rapport. But still -- do you care about the President's Day plans of someone you don't know?

Nope. Instead you were thinking, "Clearly you want something. Can you please get to it?"

Now imagine you get this email:

We would love to have you on our show to talk about your book. Our podcast regularly appears in the top 10 of 'What's Hot' in the Business category of Apple Podcasts...

Would you keep reading? I know I did.

Here's the thing. We all get cold emails, and we're all incredibly good at sniffing out boilerplate openings and forced friendliness. Even if we do keep reading, canned openings negatively impact our impression of what is to come -- and make it much less likely we'll respond positively to the actual message of the email.

Think I'm wrong? Tell me how many times you've seen the following opening lines in an email and still kept reading.

"I thought I would circle back ..."

Yes, because I didn't respond the first time you emailed. But why will I respond this time... especially when the rest of your email is just copied and pasted from your original email?

In the same vein, this won't work either:

"In case you missed this ..."

Maybe I did miss this.

Or maybe I wasn't interested.

Occasionally the recipient may have missed your original email. But know the person you're targeting. If it's someone who gets dozens of unsolicited emails a day, like, say, Tim Ferriss, then his lack of response doesn't mean he missed it. He didn't respond because he gets too many emails to respond to each one individually. If he's interested, he'll respond.

And just in case he really did miss it, find a more creative way to send another email. "In case you missed this" only ensures that even if he does see your second email, he's not going to read it.

And that's also true for:

"I'm just following up ..."

Occasionally a follow-up is warranted. If I said I would do something, and I haven't, by all means, please follow up. It's embarrassing to admit, but I sometimes do forget.

But if you're just "following up," or "circling back," or finding out if the recipient "missed this," find a more creative opening line.

Look at what you wrote in the first email. In all likelihood it was benefit-driven -- foryou. Find a way to benefit the recipient. Always give, long before you hope to receive.

"I hope this finds you well."

I get this one at least four times a day. While I appreciate the sentiment, I immediately think two things. I first wonder when Dickensian greetings came back into vogue. But more important, "I hope this finds you well" screams "We don't know each other."

And while every new friendship has to start somewhere, "I hope this finds you well" is unlikely to be the place.

That's also true for:

"I hope you had a great weekend."

Fine if it comes from a friend (even though none of my friends ever open an email that way). Otherwise it's just forced friendliness. Asking "How was the Rolex 24?" shows you know me personally. Asking "How is your next book coming?" shows you know me professionally.

Granted, "I hope you had a great weekend" is an attempt to be friendly. But really: Do you expect people to respond? Do you really want to know about their weekend? Nah. What you really care about is how they respond to the meat of your email.

In time, some professional relationships do also become personal. But when the initial contact is through email, the relationships always starts as a professional one. Work to establish that first. Then a friendship might follow.

But not if you pretend that we're already friends.

"You might be surprised to learn ..."

No, I won't be, because I won't read the rest of your email. Like fake friendliness, interest-starters feel canned and forced. If I might be surprised, shoot, go ahead and surprise me with your opening line.

The same is true for:

"Did you know ...?"

Granted, asking a question can be a way to engage readers. But not in the opening line of an email since what we all do know is that whatever you claim we don't know is something you will then solve for us, probably for a fee.

"Did you know" and, "You might be surprised to learn" are clear signals that a sales pitch is coming. Maybe that's not your intent -- but we'll assume it is.

And a couple quick ones:

"My name is ..."

I already knew that. Your name appears in the sender field.

"I would like to introduce myself ..."

Sometimes introducing yourself first is OK, but in most cases the best approach is to say what you can do for the recipient (or what you want) first.

Then, if we're interested, we'll be willing to check out whether you're the right person to provide it (or are someone we want to help).

"I know you're really busy ..."

This is always followed by "but ..." (which is a lot like saying, "I know this is going to hurt your feelings, but ..."), Acknowledging a situation and then choosing to ignore that situation is an off-putting way to start.

Instead, respect the recipient's time by getting to the point: The less fluff, the better.

"I want to ask a quick favor."

At least in my experience, a "quick favor" never turns out to be quick. And neither does the ask itself.

Here's a better way to do it. I recently received this one-line email:

Daniel Coyle's new book is about high performance teams, I would love to have him on my podcast, and I'm hoping you can connect us.

He clearly knows I know Dan, and the name of the podcast was in the sender's sig. Easy ask, and I always try to help out people I know, so I forwarded his email to Dan with one line: "Want me to connect you guys?" (I don't share people's email addresses without asking.)

Dan said yes. That's the kind of favor I'm happy to do.

But if the email had led with something like, "I am hoping you will do a quick favor for me. My name is John Doe, and in addition to running Acme Industries I am also the host of ..."

Nope. Probably not -- because I probably wouldn't have stuck with it long enough to get to the good stuff.

And that, ultimately, is the point. Your may have great intentions. You may mean extremely well. You may only be trying to be friendly, courteous, and professional.

But if you start your emails with opening lines like the ones above, most people will assume the worst -- not the best.

Find a different way to be friendly, courteous, and professional -- especially if you want your emails to actually be read.



posted Mar 6, 2018, 7:33 AM by Kim Whitlock   [ updated Mar 6, 2018, 7:35 AM ]

Do you stay up at night wondering whether your insurance will cover a wire fraud scam?  

According to a 2015 cyber and privacy insurance survey by The Betterley Report, out of 31 leading cyber insurance providers, only eight cover fraudulent wire transfer. Of those eight insurers, “a lot have further restrictions if the insured is involved in the wire fraud,” says Garrett Droege, executive director of TechAssure, an international association of technology-related risk insurance experts.[1]  

Under traditional commercial crime policies, courts draw a distinction between losses where a thief hacks the insured’s computer systems, and losses where the insured voluntarily transfers funds. Courts have found  that losses from voluntary transfer of funds, including social engineering losses, are generally not covered because they arise from an authorized transfer of funds. In addition, many commercial crime policies contain a “voluntary parting” exclusion on which the carriers will seek to rely in order to argue that coverage for these types of losses is precluded.

When negotiating your coverage you should aim for breadth and flexibility with respect to such coverage and remember that, while email is likely to be involved, it is unlikely to be the singular cause of loss. 

The language matters:  Four recent lawsuits by companies seeking coverage under similar crime policies provide useful insight to businesses looking to recover money lost to social engineering scams and other types of fraudulent transfers. In each case, employees were tricked into wiring money to cybercriminals who used fraudulent emails to impersonate legitimate vendors, clients or company executives.  Although the facts in these cases were similar, the court in each relied more on specific language of the policy to reach opposite decisions.  These four recent cases emphasize the importance of having the right language in your insurance policy for the type of frauds you are most likely to experience. 

Two recent victories for policyholders:  In perhaps the most relevant case for the type of wire fraud scam we have seen in the real estate industry, the court in Principle Solutions Group LLC v. Ironshore Indemnity Inc.[2]  granted summary judgment in favor of the policyholder, finding the language of the crime policy’s “computer and funds transfer fraud” provision is ambiguous and must therefore be interpreted in the policyholder’s favor. The fact that there were multiple steps between the initial email and the transfer does not free the insurer from its coverage obligations. 

In Medidata Solutions Inc. v. Federal Insurance Co,[3] it was found that the computer fraud provision in the crime policy covered losses that resulted from the “fraudulent entry” or changing of data in the policyholder’s computer system.  The policy at issue defined “computer system” broadly to include “communication facilities…utilized by” the insured and “data” as including any “representation of information.” Those definitions proved pivotal in the court’s decision.  Had the crime policy defined the terms more narrowly—for example, to cover only systems “owned and operated by” the company, as many policies do—the policyholder would have been out of luck.

Two Insurer Friendly Decisions:  In American Tooling Center Inc. v. Travelers Casualty and Surety Co. of America and Apache Corp. v. Great American Insurance Co, the respective courts determined that the fraudulent emails did not cause the wire transfers, people did by failing in their processes and scrutiny. Insurers commonly argue that fraudulently-induced losses are not covered because the purported “loss” was “authorized,” either because the policy excludes coverage for “authorized” transfers or only covers “unauthorized” transfers.

The computer fraud provision in Apache’s commercial crime policy extended coverage for losses “resulting directly from the use of any computer to fraudulently cause a transfer.”  The panel emphasized that the fraudulent email was just one step in an intricate scheme that ultimately led Apache employees to authorize legitimate transfers, albeit to a bogus account.[4]

Similarly, American Tooling’s crime policy extended coverage to any “direct loss” that was “directly caused by” the use of a computer.  Again,  the company took several steps between when it received the fraudster’s emails and when it wired the funds.[5]

Will you be covered?

Some Carriers are Now Offering Social Engineering Fraud Coverage on a Limited Basis.  The endorsements are designed to provide coverage when an employee is intentionally misled by electronic or written instructions from a person purporting to be a company executive or employee, vendor, client, or customer, to transfer money or property. These endorsements are often called “social engineering fraud” endorsements or “payment instruction fraud” endorsements. Some carriers will require companies seeking this type of coverage to complete a supplemental application or provide other underwriting information.

[1] The Betterely Report;

[2] The district court case is Principle Solutions Group LLC v. Ironshore Indemnity Inc., case number 1:15-cv-04130, in the U.S. District Court for the Northern District of Georgia, Atlanta Division. The appellate court case is Principle Solutions Group LLC v. Ironshore Indemnity Inc., case number 17-11703, in the U.S. Court of Appeals for the Eleventh Circuit.

[3] The district court case is Medidata Solutions Inc. v. Federal Insurance Co., case number 1:15-cv-00907, in the U.S. District Court for the Southern District of New York. The appellate court case is Medidata Solutions Inc. v. Federal Insurance Co., case number 17-2492, in the U.S. Court of Appeals for the Second Circuit.

[4] The case is Apache Corp. v. Great American Insurance Co., case number 15-20499, in the U.S. Court of Appeals for the Fifth Circuit.

[5] The district court case is American Tooling Center Inc. v. Travelers Casualty and Surety Co. of America, case number 5:16-cv-12108, in the U.S. District Court for the Eastern District of Michigan. The appellate court case is American Tooling Center Inc. v. Travelers Casualty and Surety Co. of America, case number 17-2014, in the U.S. Court of Appeals for the Sixth Circuit.

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