In Gunderson v. Fire Ins. Exchange (1995) 37 Cal.App.4th 1106, an insurer declined to defend its insured against a lawsuit seeking declaratory relief quieting title to an easement and injunctive relief enjoining the insured from asserting or exercising any claim to the easement. (Id. at p. 1110.) Affirming the trial court's grant of summary judgment in favor of the insurer, the Court of Appeal explained "there were no claims of either tangible property damage or bodily injury in the complaint." (Id. at p. 1115.) Rejecting the insured's argument that "there was a potential for liability under the policy because the third party claimant could have made a claim for 'physical injury to or destruction of tangible property' in connection with a fence across a portion of the easement which the insured removed at the outset of the dispute," the court explained that "an insured may not trigger the duty to defend by speculating about extraneous 'facts' regarding potential liability or ways in which the third party claimant might amend its complaint at some future date." (Id. at pp. 1114-1115.)