A federal district court in California has denied an insurer’s motion to dismiss based on a “related claims” argument because the coverage litigation pleadings did not contain sufficient information to resolve the dispute as a matter of law. Rancho Tehama Ass’n v. Federal Ins. Co., 2015 WL 3454610 (E.D. Cal. May 29, 2015). The insurer denied coverage for a lawsuit on the basis that it was deemed related to a claim made before the start of the insured’s claims-made policy and moved to dismiss the insured’s coverage action seeking coverage for the lawsuit on that basis. The court concluded, however, that the issue of whether the underlying lawsuit and the prior matter are “related claims” “necessarily entails a factual inquiry, which is premature for the Court to conduct on a motion to dismiss.”