Advanced Network, Inc. v. Peerless Ins. Co

In Advanced Network, Inc. v. Peerless Ins. Co. (2010) 190 Cal.App.4th 1054, the court held that "'loss of use' and 'loss' are not interchangeable for insurance purposes." (Id. at p. 1063.) "Coverage for 'loss of use' does not apply to an underlying action in which the claimant seeks only the replacement value of converted property." (Id. at p. 1064.) The court explained: "the measure of damages of a stolen car cannot be its rental value ad infinitum on the ground there was a permanent 'loss of use' of the property. Interpreting the term 'loss of use' to include a permanent loss would lead to absurd results." (Ibid.)