Federal Judge William Hart ruled that a liability insurer owed a defense to a seller of toys that were manufactured in China in ACE American Insurance Co. v. RC2 Corp. Inc. et al., 568 F. Supp. 2d 946 (N.D. Ill. 2008). The allegedly harmful toys involved, contained lead paint which gave rise to claims for bodily injury. In a subsequent ruling involving components of the claim for reimbursable defense costs, the court made reductions for voluntary payments and work it characterized as “non-legal.” ACE American Insurance Co. v. RC2 Corp. Inc. et al., 2009 WL 1137904 (N.D. Ill., April 23, 2009).

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