11 In what has been called the triple trigger, courts ruled that the occurrence that “triggers” the insurer liability was the initial inhalation of asbestos fibers, the continued exposure to the hazard, or the diagnosis of the disease. This decision said that all insurers that had provided coverage from the time of inhalation through manifestation of an asbestos-related disease are liable for defense and indemnification costs. In some cases, the firms had been uninsured for extended periods, and the courts sought an interpretation that would find coverage under any (or all) of their expired contracts. Insurance Company of North America v. Forty-Eight Insulations, Inc., 633 F.2d 1212 (6th Cir., 1980) cert. denied 102 S. Ct. 686 (1981); Eagle-Picher Industries, Inc. v. Liberty Mutual Insurance Co., 523 F. Supp. 110 (D. Mass., 1981): Keene Corporation v. Insurance Company of North America, 667 F.2d 1034 (D.C. Cir., 1981).
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