In a noteworthy decision on the coverage of data breaches by commercial general liability (CGL) policies, the United States Court of Appeals for the Fourth Circuit affirmed a lower court’s August 2014 holding that Portal Healthcare Solutions LLC (Portal) is covered under its CGL policies with The Travelers Indemnity Company of America (Travelers). The unpublished opinion in Travelers Indemnity Company of America v. Portal Healthcare Solutions, LLC, No. 14-1944 (4th Cir. Apr. 11, 2016) found that Travelers has a duty to defend Portal for a civil lawsuit pending in New York state court related to the disclosure of confidential patient information.