Interpreting an additional insured endorsement, the U.S. District Court for the Northern District of Illinois recently held that the it is the scope of the named insured’s work—not the additional insured’s work—that governs the availability of coverage under the policy. Old Republic Ins. Co. v. Leopardo Companies, Inc.,No. 14 C 02421 (N.D. Ill. Mar. 11, 2015). As part of the underlying action, Leopardo Companies, Inc. (“Leopardo”) was hired as the general contractor to perform renovation work on the Millennium Knickerbocker Hotel in Chicago. Leopardo then entered into a subcontractor agreement with Edwards Engineering (“Edwards”), under which Edwards would perform discrete fan coil unit work. Pursuant to the subcontractor agreement, Leopardo was included as an additional insured on a commercial general liability (“CGL”) policy issued by Old Republic to Edwards as the named insured. The property owner later sued Leopardo in a breach of contract action, alleging that defectively designed fan coil units had leaked and caused damage to the guestroom ceilings, walls, fit, and finishes. Using its additional insured status, Leopardo sought coverage from Old Republic under the policy issued to Edwards. Old Republic agreed to defend subject to a reservation of rights, but filed a two-count declaratory judgment action seeking (i) a declaration that it had no duty to defend or indemnify and (ii) recoupment of defense costs incurred. On cross motions for summary judgment, the parties sought a ruling as to whether the underlying action alleges ‘property damage’ caused by an ‘occurrence’ required to trigger Old Republic’s duty to defend. Applying Illinois law, the court first held that a covered ‘occurrence’ in this context requires that a construction defect damage work other than that furnished by the insured. Old Republic argued that it had no duty to defend or indemnify because the underlying complaint alleged no damage to anything other than Leopardo’s own renovation work. Directing the party’s attention to the plain language of the insurance policy, the court held that it is in fact Edwards’ work—not Leopardo’s—that determines whether there is a covered ‘occurrence.’ While the endorsement that added Leopardo as an additional insured provides coverage for property damage “caused in whole or in part by your acts or omissions,” the policy separately defined the term “your” as referring only to the named insured (i.e., Edwards). The certificate of insurance issued to Leopardo likewise confirmed that Leopardo was included as an additional insured “as respects work performed by Edwards.” Because the underlying complaint plainly alleged damage to work other that performed by Edwards, the court held that it alleged an ‘occurrence’ sufficient to trigger Old Republic’s duty to defend Leopardo in the underlying action.