Two different courts recently reached opposite conclusions in determining whether a subpoena constitutes a “written demand for non-monetary relief,” and therefore a “Claim,” as commonly defined by many insurance policies. In Employers’ Fire Insurance Co. v. ProMedica Health Systems, Inc., 524 F. App’x 241 (6th Cir. 2013) (No. 12-3104), the Sixth Circuit interpreted the term “relief” according to its dictionary definition to mean “the redress or benefit . . . that a party asks of a court.” 524 F. App’x at 251. Applying this definition to a subpoena issued by the Federal Trade Commission (FTC), the Sixth Circuit concluded that a subpoena does not seek relief or redress from a court, and therefore cannot form the basis of a “Claim.” Id. at 251-52. The New York state courts, however, reached a contrary result using the same definition of “relief” in Syracuse University v. National Union Fire Insurance Co. of Pittsburgh, Pa., 975 N.Y.S.2d 370 (N.Y. Sup. Ct.) (No. 2012EF63) (table), aff’d, 976 N.Y.S.2d 921 (N.Y. App. Div. 2013), concluding that federal and state issued grand jury subpoenas are, in fact, “Claims.” Relying on the full dictionary definition of “relief,” which includes “redress or benefit . . . that a party asks of a court – also termed remedy,” the court noted the inclusion of the word “remedy,” which is itself broadly defined as a “means of enforcing a right or preventing or redressing a wrong.” Subpoenas, the court held, seek to enforce the investigating entity’s rights and redress a potential wrong. In addition, the court held that the relief sought by a subpoena is the provision of information or the production of documents. These recent decisions reveal that the availability of coverage for a particular investigation or subpoena may be jurisdiction-specific, as well as dependent on which definition of “Claim” appears in the policy at issue.