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This Article is written by Bhumika Meena of B.A.LLB of 5th Semester of Dharmashastra National Law University, Jabalpur, an intern under Legal Vidhiya
ABSTRACT
Cyber insurance has become an essential precaution against cyberattacks and data breaches, including coverage for data breach response costs, business disruption losses, cyber extortion, legal expenditures, and regulatory fines. However, insurers often exclude losses due to human error, contractual liabilities, pre-existing vulnerabilities, and acts of war or terrorism, leading to complex debates over policy interpretation and claims. The paper also delves into new themes such as parametric cyber insurance, AI-driven risk assessment, legislative changes, and the increasing integration of cybersecurity measures with insurance. As cyber dangers change, insurers and policyholders must adapt to maintain efficient risk management.
KEYWORDS
Cyber Insurance, Coverage, Cybersecurity, Risk Management, Data Breach, Exclusions, Emerging Trends
INTRODUCTION
A specific type of insurance coverage called cyber insurance is intended to lessen monetary damages brought on by events involving the internet, such as network outages, data breaches, and cyberattacks. It usually includes both first-party and third-party coverages, including liability claims, regulatory fines, and incident response expenses. As personal and company operations become more digitally connected, cyber insurance has become an essential part of risk management plans.
The frequency of cyberthreats has sharply increased in the digital age. Large-scale data breaches, phishing scams, and ransomware assaults are become commonplace threats rather than rare incidents. Phishing, for example, is said to be responsible for 41% of all cyber incidents and is frequently used as the first attack vector. Ransomware attacks also increased by 84% in 2023, creating significant operational and financial difficulties. With 40% of smaller organizations reporting cyber incidents, these concerns impact small and medium-sized businesses in addition to big corporations.
In light of this environment, getting cyber insurance has become essential for both individuals and businesses. To handle the costs of cyber disasters, including legal fees, forensic investigations, and business interruption losses, businesses need to have strong insurance plans. Cyber insurance offers people financial security and peace of mind by guarding against identity theft and online fraud. Cyber insurance is essential for building resilience in the face of digital vulnerabilities as cyber hazards continue to grow in complexity and scale.
DEFINITION
Cyber insurance, sometimes referred to as cyber liability insurance, is a type of specialty insurance intended to shield companies against monetary damages brought on by ransomware attacks, data breaches, and other online dangers. It provides coverage for third-party liabilities (expenses resulting from claims by outside parties) as well as first-party losses (expenses directly incurred by the business). This covers costs for reputational harm, legal bills, company interruption, and data restoration.
Cyber insurance, according to the Federal Trade Commission (FTC), is “an option that can help protect your business against losses resulting from a cyber-attack.”[1]
Cyber insurance essentially acts as a financial safety net, helping businesses to control the risks brought on by the growing sophistication and frequency of cyberattacks.
LEGAL FRAMEWORK OF CYBER INSURANCE POLICIES
Numerous national and international laws that impact policy structures and compliance requirements make up the legal framework governing cyber insurance.
Information Technology Act of 2000 in India: The Information Technology Act, 2000 (IT Act) is the foundation for cybersecurity and data protection in India. Any corporate entity managing sensitive personal data is required by Section 43A of the IT[2] Act to establish “reasonable security practices and procedures.” Negligence resulting from failure to do so may give rise to claims for compensation and liability. Furthermore, guidelines for data protection are outlined in the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011, which were created under the IT Act. These rules include requirements for privacy policies, data collection, and disclosure practices.[3]
General Data Protection Regulation (GDPR) from a global perspective
Since it went into effect in 2018, the General Data Protection Regulation (GDPR) of the European Union has established a global standard for data protection. Regardless of the organization’s location, it places strict standards on anyone managing the personal data of EU citizens. Significant fines of up to €20 million or 4% of yearly global turnover, whichever is higher, may be imposed for noncompliance.[4] Because insurers evaluate an organization’s compliance posture when underwriting policies, the GDPR has had a substantial impact on cyber insurance. Strong data protection policies may offer better terms to businesses, whereas noncompliant policies could result in higher premiums or exclusions.
Regulatory Bodies’ Function
India: The insurance industry, including cyber insurance products, is governed by the Insurance Regulatory and Development Authority of India (IRDAI). IRDAI stresses the significance of insurers comprehending cyber hazards and creating suitable solutions, even though exact criteria for cyber insurance are still being developed.
United States: To help state insurance regulators manage cyber risks and encourage data security among insurers, the National Association of Insurance Commissioners (NAIC) offers model legislation and guidelines.
Cyber Insurance Policies’ Adherence to Data Privacy Laws
To guarantee the validity of coverage, cyber insurance policies must be in compliance with current data privacy legislation. For example, depending on policy language and jurisdictional interpretations, some fines and penalties under laws like the GDPR might not be insurable. Companies should carefully examine the exclusions in their policies and get legal advice to make sure that their insurance coverage aligns with their compliance requirements.[5]
Difficulties Without a Standard International Framework
The following issues arise from the absence of a regulated international framework for cyber insurance:
Inconsistent Regulations: Developing comprehensive cyber insurance policies that are globally applicable is made more difficult by disparate data protection rules across jurisdictions.
Coverage Discrepancies: Coverage gaps may result from differing legal interpretations of the insurability of fines and penalties.
Variability in Risk Assessment: Various legal restrictions have an impact on how insurers evaluate and value cyber risks around the world.
Businesses that operate globally must manage these complications by adjusting their cyber insurance plans to conform to local laws and looking for plans that provide flexibility in a variety of legal contexts.
In conclusion, firms must comprehend how cyber insurance and the laws governing data protection interact in order to guarantee proper coverage.
UNDERSTANDING COVERAGE
Common Coverages in Cyber Insurance Policies
First Party Coverage
The goal of first-party coverage is to safeguard the covered company by paying for its own losses and rehabilitation. It focuses on the organization’s immediate financial effects, including recovery costs, revenue loss, and reputation restoration.
Third-Party Coverage
The goal of third-party coverage is to shield the company from outside claims, including as legal action, penalties from the government, and liabilities resulting from injuries to other individuals or organizations brought on by the insured company’s cyber failures.
Cyber insurance policies are designed to mitigate the financial and operational impacts of cyber incidents. Key coverages typically include:
- Data Breach Response Costs: This coverage addresses expenses associated with managing a data breach, such as notifying affected individuals and providing credit monitoring services. These measures are crucial for maintaining customer trust and complying with legal obligations.
- Liability Coverage for Data Privacy Violations: This aspect of cyber insurance protects businesses against legal claims arising from the unauthorized disclosure of personal or confidential information. It covers legal defense costs and any settlements or judgments related to data privacy breaches[6].
- Losses Due to Business Interruption Caused by Cyber Incidents: Cyberattacks can disrupt operations, leading to significant revenue loss. This coverage compensates for income lost during the downtime and may also cover additional expenses incurred to restore normal business functions.
- Costs of Legal Consultations and Forensic Investigations: To ascertain the scope and cause of a cyber event, forensic investigations are necessary. Legal advice aids in navigating any legal issues and regulatory obligations. These expenses are frequently covered by cyber insurance plans in order to maintain compliance and guide mitigation tactics.
- Cyber Extortion Coverage for Ransomware Payments: This coverage helps cover the costs of responding to extortion demands, such as ransom payments and expenditures associated with negotiating with hackers, in the case of a ransomware attack.[7]
Nuances of Industry-Specific Coverage
Because every industry faces different cyberthreats, customized insurance solutions are required:
- Healthcare: Healthcare organizations may need coverage for Health Insurance Portability and Accountability Act (HIPAA) violations and related penalties because to the sensitive nature of patient data.
- Financial Services: Businesses in this industry frequently want for protection against losses from phishing techniques that target financial transactions as well as coverage for fraudulent wire transfers.
- Retail: In the event of a data breach, retailers who handle substantial amounts of credit card data may require coverage for Payment Card Industry Data Security Standard (PCI DSS) assessments and associated fines.
Organizations can more accurately evaluate their exposure to cyber risk and choose the best insurance plans to reduce possible losses by being aware of these standard coverages and industry-specific quirks.
Some significant findings are revealed by the examination of covered and excluded losses in cyber insurance. First, there is a distinct distinction between third-party losses (costs resulting from legal actions) and first-party losses (costs directly paid by the business). This differentiation aids in establishing insurance coverage limits and sublimits. Cleanup costs, which include things like maintaining the company’s reputation and adhering to rules following a cyber breach, are the most frequently covered losses. Data restoration and loss of business revenue are examples of additional covered expenses that are directly related to the actual cyber occurrence. Cleanup costs appear to be more costly or easier to quantify, which could be why they are commonly covered. Direct and indirect expenses, however, appear to be roughly balanced, according to several research.
Cyber insurance coverage may need to change to cover or exclude new risk types as technology advances, particularly with the proliferation of connected devices. One policy, for instance, does not cover losses resulting from product faults; but, as the number of Internet of Things (IoT) devices and cyberattacks via these devices increases, further exclusions might be introduced. Furthermore, although regulations frequently concentrate on conventional computers and networks, they don’t necessarily address emerging hazards like drones or mobile devices, which may become significant as system interdependencies grow.
Insurance companies may also exclude some risks, such as acts of terrorism, ransomware, or war, because they understand that cyber disasters may result in collateral harm. Actually, a lot of plans don’t cover these kinds of claims, but others still cover extortion or ransom. Similar exclusions may be added to other plans as cyber concerns increase. There is continuous dispute about whether malevolent cyber incidents can lead to these “act of war” exclusions.[8]
COMMON EXCLUSIONS IN CYBER INSURANCE POLICIES
When considering cyber insurance policies, it’s crucial to understand common exclusions that may limit coverage. Typical key exclusions are:
Acts of Terrorism or War: A lot of insurance don’t cover losses from cyberwarfare or other acts of terrorism or war. Certain insurers, however, give separate coverage for political violence or grant exceptions for cyberterrorism[9].
Pre-existing Vulnerabilities or Known Threats: Generally speaking, incidents resulting from vulnerabilities that were known before to the policy’s creation are not covered. In order to guarantee appropriate coverage during underwriting, prior incidences must be disclosed.[10]
Negligent Insider Threats: Policies may not cover breaches brought on by internal carelessness, such as weak security procedures or improper configuration management.
Noncompliance with Data Protection Laws: Generally, coverage does not cover fines, penalties, or sanctions resulting from a company’s failure to comply with data protection laws.
Fines and Penalties Not Covered by Law: Cyber insurance policies often do not cover fines and penalties that a firm is legally required to pay, whether they be criminal, civil, or regulatory. Intellectual Property Loss: Since intellectual property insurance normally covers these types of losses, theft or loss of intellectual property, such as trade secrets or patents, is generally not covered.
It’s crucial to carefully go over the terms and conditions of a cyber insurance policy in light of these exclusions. Businesses and individuals can take extra precautions to reduce uncovered risks by being aware of coverage restrictions and knowing the tiny print. Speaking with insurance experts can help clarify matters and customize plans to meet certain requirements.
EMERGING TRENDS IN CYBER INSURANCE
The growing frequency and sophistication of cyber threats is driving a rapid evolution in the cyber insurance market. Important new trends include:
1. A Rise in Demand
In order to reduce possible losses, companies are looking for more specialized cyber insurance plans as cybercrime increases. Premiums for cyber insurance doubled between 2017 and 2020 and again between 2020 and 2022, indicating the market’s tremendous expansion.
2. Policy Sophistication
To cover more specialized risks, such as those associated with cloud computing and artificial intelligence, insurers are expanding their product lines. To tackle rapidly evolving digital threats, such as those posed by deepfakes and artificial intelligence, Coalition, for example, offers complete cyber insurance coverage.
3. Increasing Premiums
Recent data shows a reversal, with premiums rising as cyber threats grow more common and complex, despite a period of dropping rates brought on by stronger cybersecurity measures. Large cyber claims (above €1 million) grew in frequency by 14% and in severity by 17% in
the first half of 2024, which led to higher premiums.
4. Integrating Risk Management
Policies are increasingly including recommendations or mandates for risk mitigation, like upholding specific cybersecurity procedures. Secure works has established strategic partnerships with top cyber insurance companies to deliver all-inclusive risk management solutions that integrate insurance coverage and cybersecurity knowledge.[11]
5. Regulations Concerning Data Protection and Privacy
Cyber insurance plans’ coverage and exclusions are being influenced by international laws such as the California Consumer Privacy Act (CCPA) and the General Data Protection Regulation (GDPR). In order to comply with these laws, insurers are modifying their products, which has an impact on the coverage and structure of policies.
6. Customized Regulations
Policies are becoming increasingly industry-specific, with coverage tailored to industries like technology, healthcare, and finance. This strategy enables insurers to provide more pertinent and efficient coverage by addressing the particular risks connected to certain industries.
7. Reinsurance for Cybersecurity
Reinsurance is becoming more and more popular in the cyber insurance industry as a way to distribute risk. By spreading the risk with other organizations, this trend assists insurers in managing possible significant losses from cyber catastrophes.
8. Collaborations Between Cybersecurity Providers and Insurers
Insurers and cybersecurity companies are increasingly working together to provide complete risk management and insurance solutions. For instance, Cloudflare helps clients lower their insurance rates and enhance cyber risk management by collaborating with top cyber insurers and incident response companies.
These patterns demonstrate how the cyber insurance industry is dynamic and changes to meet new threats and changing business requirements.[12]
ENFORCEMENT MECHANISMS AND REMEDIES
While cyber insurance is a valuable component of a comprehensive risk management strategy, it should be complemented by robust cybersecurity measures to effectively mitigate cyber threats. To assist businesses in strengthening their cybersecurity posture, the National Cyber Security Centre (NCSC) has developed an interactive Cyber Assessment Framework (CAF). This tool systematically evaluates an organization’s technology infrastructure, operational practices, and security protocols.
By completing a concise questionnaire, organizations can identify potential vulnerabilities and receive tailored recommendations to enhance their cybersecurity defenses, thereby facilitating easier access to cyber insurance coverage.
Businesses usually need to put in place a number of crucial cybersecurity measures in order to be eligible for cyber insurance coverage:
- Employee Cybersecurity Training: By teaching staff members how to recognize and handle threats like ransomware and phishing, regular training programs help to lower human error, which is a major contributor to data breaches.
- Multi-Factor Authentication (MFA): By demanding several forms of authentication, MFA adds an additional layer of protection and greatly reduces the possibility of unwanted system access.
- Regular Data Backups: Regular and secure data backups reduce downtime and data loss by guaranteeing that important data can be restored in the case of a cyberattack.
Identity and Access Management (IAM): Strong IAM procedures lower the risk of both internal and external breaches by ensuring that only authorized users have access to sensitive data. - Data Classification Policies: By classifying data according to sensitivity levels, companies may implement the right security measures and guarantee that the most important data is protected to the highest degree possible.
- Endpoint Detection and reaction (EDR): By using EDR solutions, an organization can improve its capacity to quickly identify and address cyber risks by enabling continuous monitoring and reaction to threats across all endpoints.[13]
The whole Businesses can enhance their cybersecurity posture and increase their eligibility for comprehensive cyber insurance coverage by putting these strategies into practice.
In order to guarantee that policyholders receive the proper assistance after a cyber incident, enforcement procedures and remedies within cyber insurance plans are essential. Organizations can more successfully negotiate the complexities of cyber insurance by being aware of the claim’s procedure, dispute resolution procedures, and potential obstacles.
Processing Claims and Resolving Disputes
Policyholders should contact their insurer as soon as they become aware of a cyber event. Notification must be sent promptly because any delays could compromise coverage. Insurers usually designate a breach coach—typically a cybersecurity-focused legal specialist—to oversee the response and claims procedure after notification. It is anticipated that the policyholder will assist the insurer in its inquiry by supplying the required paperwork and granting access to the pertinent systems. This cooperative method speeds up claim resolution and enables accurate assessment.
Evaluating Liability and Authenticity
To evaluate the veracity of cyber incidents and ascertain the insured’s obligation, insurers use a variety of methods. Forensic investigations are frequently used in this procedure to determine the scope and cause of the breach. Evaluations are conducted on elements like adherence to regulatory standards, the efficacy of security measures put in place, and conformity with policy conditions. The results of this evaluation have an impact on the policy’s coverage and benefits.[14]
Redress for Unjust Claim Refusals
Policyholders have a number of options in the event that a claim is rejected. First, they can use the insurer’s internal dispute resolution procedure to appeal the ruling. Depending on the conditions of the policy, outside alternatives like mediation or arbitration may be sought if the disagreement cannot be settled. Litigation may be required in certain situations to contest the denial. Navigating these procedures and defending the policyholder’s rights might be made easier by hiring legal counsel with experience in insurance law.
Litigation Options and Arbitration Clauses
Arbitration clauses are frequently included in cyber insurance contracts as a way to settle disagreements out of court. Compared to typical litigation, arbitration may provide a quicker and more private resolution. Policyholders must, however, be aware of the ramifications of such terms, such as the possible renunciation of the right to a jury trial and the restricted appeals process. Policyholders may turn to litigation, which can be more expensive and time-consuming, to settle disagreements in the absence of arbitration agreements.[15]
Enforcement Difficulties
There are particular difficulties in enforcing cyber insurance claims. One major challenge is identifying the origin of a cyberattack, which is frequently difficult because of the advanced techniques used by attackers to hide their identity. Conflicts may also emerge about how the policy should be interpreted, such as whether or not particular kinds of cyber incidents are covered. Enforcement efforts may be made more difficult by differences in policy wording and the dynamic nature of cyberthreats. To bolster their claims and speed up the enforcement process, policyholders should keep thorough records of their cybersecurity precautions and incident response efforts.
CASE LAWS
P.F. Chang’s China Bistro, Inc. v. Federal Insurance Co.
A data breach occurred at P.F. Chang’s, exposing the credit card information of its patrons. For the liabilities expenses brought on by the breach, they asserted coverage under their cyber insurance policy. Because the policy did not cover such liabilities, the insurer refused coverage.
The court determined that the insurer was not covered by the insurance policy since P.F. Chang’s expenses were not covered by it. This instance made it clear how crucial it is to comprehend the exclusions in cyber insurance policies.[16]
Mondelez International, Inc. v. Zurich American Insurance Co.
The Not Petya virus assault caused a large loss for Mondelez. Under their cyber insurance policy, they submitted a claim. Citing a “war exclusion clause,” Zurich refuted the allegation, claiming that the attack was connected to state-sponsored operations. The difficulties in interpreting cyber insurance plans, particularly with regard to exclusions pertaining to acts of terrorism or war, are highlighted by this ongoing case.[17]
National Insurance Co. Ltd. v. Hindustan Safety Glass Works Ltd.
The interpretation of insurance policy provisions in relation to industrial damages was the focus of this case. The court emphasized the idea that the insured should always win where there are discrepancies in insurance arrangements. The court decided in the insured’s favor, highlighting the significance of precise and explicit policy language. This decision may have an impact on how Indian courts read unclear or exclusionary language in cyber insurance plans.[18]
CONCLUSION
Cyber insurance is a crucial risk management instrument in the larger context of cybersecurity, offering both financial security and assistance in lessening the effects of cyber events. By providing companies with a safeguard against the growing risks of ransomware, data breaches, and other cyberattacks, it enhances strong cybersecurity procedures. Its efficacy, however, rests in its careful incorporation into a company’s entire risk management plan.
It is essential to comprehend the subtleties of policy terms since exclusions or coverage gaps may result in unanticipated liabilities. Companies need to keep up with new developments, like improvements in ransomware-specific coverage and the impact of laws like the GDPR and India’s Digital Personal Data Protection Act.
Establishing robust internal cybersecurity procedures is equally crucial. In addition to lowering cyber risks, proactive efforts like frequent vulnerability assessments, staff training, and system updates can result in better insurance terms and cheaper premiums.
In order to guarantee resilience in a world that is becoming more digitally connected and networked, cyber insurance should ultimately be seen as a strategic layer of protection that complements proactive and reactive cybersecurity measures.
REFERENCES
- Federal Trade Commission, https://www.ftc.gov/business-guidance/small businesses/cybersecurity/cyber-insurance, ( last visited Jan. 25, 2025).
- Murray Law Group, https://murraylawgroup.com/insurance-law/types-of-claims/cyber-insurance-claims, (last visited Jan. 25, 2025).
- Hungtington, https://www.huntington.com/Commercial/insights/risk-management/cyber-insurance-claims-process, (last visited date: Jan. 25, 2025).
- [1] David Finz, Navigating the Cyber Insurance Claims Process, ALLIANT, (Jan. 25, 2025, 4:18 PM), https://alliant.com/news-resources/article-navigating-the-cyber-insurance-claims-process/.
- Andrew S. Nadolna, Esq., Adrienne Publicover, Esq., and Daniel B. Garrie, Esq., Why Arbitration Clauses May Make Sense in Cyber Insurance Policies, JAMSADR, (Jan. 25, 2025, 4:28 PM), https://www.jamsadr.com/.
- P.F. Chang’s China Bistro, Inc. v. Fed. Ins. Co., No. 2:15-cv-01322-SRB, 2016 WL 3055111 (D. Ariz. May 31, 2016).
- Orlaith Traynor, 6 Essential Cyber Insurance Requirements Your Business Needs to Meet, CYBELANGEL, (Jan. 25, 2025, 1:02 PM), https://cybelangel.com/cyber-insurance-requirements/
- CYBER INSURANCE,2020 RESOURCES FOR MEASURING CYBERSECURITY Report Author(s): Kathryn Waldron Published by: R Street Institute (2019) Stable URL: https://www.jstor.org/stable/resrep26979.5
- Content analysis of cyber insurance policies: how do carriers price cyber risk? Sasha Romanosky, Lillian Ablon, Andreas Kuehn, Therese Jones, Journal of Cybersecurity, Volume 5, Issue 1, 2019, tyz002.
- Margaret A. Reetz, Lauren B. Prunty, Gregory S. Mantych & David J. Hommel, Cyber Risks: Evolving Threats, Emerging Coverages, and Ensuing Case Law Symposium, HEINONLINE, 727 (2018), ( last visited Feb. 6, 2025), 122PennStLRev727.pdf.
[1] Federal Trade Commission, https://www.ftc.gov/business-guidance/small-businesses/cybersecurity/cyber-insurance, ( last visited Jan. 25, 2025).
[2] Information Technology Act, 2000, § 43A, No. 21, Act of Parliament, (India).
[3] Information Technology (Reasonable security practices and procedures and sensitive personal data or information) Rules, 2011.
[4] Jones Day, https://www.jonesday.com/en/insights/2018/11/gdprs-potential-fines-and-other-exposures-raise-cy, ( last visited Jan. 25, 2025).
[5] Lauri Floresca, GDPR Liability, Data Protection, And Fines: Will My Cyber Insurance Cover Them, WOODRUFF SAWYER, (Jan. 25, 2025, 3:53 PM), https://woodruffsawyer.com/insights/general-data-protection-regulation-cyber-insurance.
[6] Dan Burke, Cyber 101: Understand the Basics of Cyber Liability Insurance, WOODRUFF SWAYER, ( Jan. 25, 2025, 10:14 AM), https://woodruffsawyer.com/insights/cyber-101-liability-insurance.
[7] John Ciarlone, Cyber Security Insurance In This Digital Age, HUMMINGBIRD NETWORKS, (Jan. 25, 2025, 10:10 AM), https://services.hummingbirdnetworks.com/blog/understanding-cyber-insurance-a-comprehensive-guide.
[8] Sasha Romanosky, Lillian Ablon, Andreas Kuehn, Therese Jones, Content analysis of cyber insurance policies: how do carriers price cyber risk? Volume 5, OXFORD ACEDEMIC, 2019.
[9] Eleanor Ruiz, Navigating common exclusions in cyber policies, REED SMITH, (Jan. 25, 2025, 12:40 PM), https://www.reedsmith.com/en/perspectives/cyber-insurance-claims/2023/06/navigating-
[10] PROWRITERS, https://prowritersins.com/cyber-insurance-blog/how-does-cyber-insurance-work/?,(last visited Jan. 25, 2025).
[11] Tony Kirtley, SecureWorks: Strengthening Partnerships in the Cyber Insurance Market, SECUREWORKS BLOG (Jan. 25, 2025, 4:58 PM), https://www.secureworks.com.
[12] Margaret A. Reetz, Lauren B. Prunty, Gregory S. Mantych & David J. Hommel, Cyber Risks: Evolving Threats, Emerging Coverages, and Ensuing Case Law Symposium, HEINONLINE, 727 (2018).
[13] Orlaith Traynor, 6 Essential Cyber Insurance Requirements Your Business Needs to Meet, CYBELANGEL, (Jan. 25, 2025, 1:02 PM), https://cybelangel.com/cyber-insurance-requirements/
[14] David Finz, Navigating the Cyber Insurance Claims Process, ALLIANT, (Jan. 25, 2025, 4:18 PM), https://alliant.com/news-resources/article-navigating-the-cyber-insurance-claims-process/.
[15] Andrew S. Nadolna, Esq., Adrienne Publicover, Esq., and Daniel B. Garrie, Esq., Why Arbitration Clauses May Make Sense in Cyber Insurance Policies, JAMSADR, (Jan. 25, 2025, 4:28 PM), https://www.jamsadr.com/.
[16] P.F. Chang’s China Bistro, Inc. v. Fed. Ins. Co., No. 2:15-cv-01322-SRB, 2016 WL 3055111 (D. Ariz. May 31, 2016).
[17] Mondelez Int’l, Inc. v. Zurich Am. Ins. Co., No. 2018-L-011008 (Ill. Cir. Ct. Oct. 10, 2018).
[18] National Ins. Co. Ltd. v. Hindustan Safety Glass Works Ltd., (2017) 5 SCC 776.
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