Determining the date on which a potentially insured injury occurred is central to the question of which insurance policy or policies may apply to provide coverage for the resulting loss. This is often referred to as the “trigger” of coverage—the date the injury or damage is deemed to have taken place. Analyzing the “trigger” of coverage can be complex for insurance claims involving injury or damage resulting in a loss that is cumulative and occurs over a period of time, and courts have built up a body of jurisprudence applying a “continuous trigger” rule to long-tail liability claims involving bodily injury or property damage in the environmental context. In FountainCourt Homeowners’ Association v. FountainCourt Development, LLC380 P.3d 916 (Or. 2016), a construction defect case, the Oregon Supreme Court issued a ruling thatsupports an extension of the “continuous trigger” rule to certain construction defect claims. During the relevant period, the policyholder had been insured by two different insurers under three different non co-extensive policies. Both insurers accepted the policyholder’s tender of defense subject to a full reservation of rights, arguing that the water damage at issue was cumulative, and that it was not possible to determine how much water damage had occurred during each of the three separate policy periods. The policyholder argued, and the trial court agreed, that the policyholder had satisfied its prima facie burden of proving coverage under the policy, and that the insurers had failed to meet their burden of proving what portions, if any, of the judgment and damages were excluded by the policy. The appellate court later affirmed the trial court’s finding on the merits. The Oregon Supreme Court likewise affirmed the lower courts’ decisions, applying the continuous trigger rule to the construction defect context. The Court found that the water damage was “continuous damage . . . over the course of multiple policy periods” and governed by the “continuous trigger” rule. It explained that “although the damage at issue . . . had begun to occur before the policies were in effect, and continued to occur after the policies were no longer in effect, coverage under those policies was nonetheless “triggered” because the damage was ongoing during the policy periods.”