Certain Underwriters at Lloyd's, London and Certain London Market Insurance Companies v. Chicago Bridge & Iron Company, 406 S.W.3d 326

CB&I faced asbestos exposure claims from Bogalusa Mill workers; CB&I built or installed structures with asbestos-containing parts between 1936 and 1965.
Certain Underwriters at Lloyd’s and London Market Insurance Companies insured CB&I; CB&I sought reimbursement for defense and settlements.
Ten representative Bogalusa Mill claimants were used to test whether settlements were reasonable in anticipation of liability; a jury found some settlements not reasonable.
The trial court entered judgment in CB&I’s favor on collateral estoppel and coverage issues; London challenged several rulings on appeal.
CB&I cross-appealed arguing that completed operations claims constitute a single occurrence; the court addressed multiple insurance-coverage issues under Illinois law.
Court held that collateral estoppel from Chicago Bridge applies, and that the asbestos claims arise from a single occurrence; London’s defenses were rejected on multiple issues.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Collateral estoppel applies to London’s coverage issue	London argues Chicago Bridge is distinguishable and not controlling.	CB&I argues Chicago Bridge controls and law has not changed.	Collateral estoppel applied; issue resolved against London.
Whether the claims arise from a single occurrence	London contends there are multiple occurrences due to time/space variation.	CB&I contends a single occurrence due to exposure to the same general conditions.	Single occurrence; CB&I prevailed on this issue.
Whether London must indemnify defense costs from dismissed claims	London should only indemnify for costs from covered occurrences.	Ultimate net loss/defense costs are recoverable as indemnity under the policy.	London must indemnify defense costs including dismissed claims.
SIRs—number applicable to the single occurrence	Three SIR periods; CB&I must satisfy each SIR per period.	One SIR per occurrence suffices.	One SIR per occurrence; CB&I required to satisfy a single SIR.
Compliance with notice and definite claim provisions	Notice was adequate; definite claim defense should not apply.	Notice and definite claim defenses were properly raised and applicable.	Notice compliance upheld; definite claim defense failed as a matter of law.

Chicago Bridge & Iron Co. v. Certain Underwriters at Lloyd's, London, 797 N.E.2d 434 (Mass. App. Ct. 2003) (all-sums allocation and occurrences defined; coverage outside policy period)
Zurich Ins. Co. v. Raymark Indus., Inc., 514 N.E.2d 150 (Ill. 1987) (rejection of pro rata allocation; all-sums approach under certain policies)
U.S. Gypsum Co. v. Admiral Ins. Co., 643 N.E.2d 1226 (Ill. App. Ct. 1994) (exposure-based injury and coverage scope; relevance to occurrence timing)
Nicor, Inc. v. Associated Electric & Gas Ins. Servs. Ltd., 860 N.E.2d 280 (Ill. 2006) (continuity of exposure; multiple vs. omnibus occurrence analysis)
Addison Ins. Co. v. Fay, 905 N.E.2d 747 (Ill. 2009) (time-space test; interpretation of occurrence and related tests)