In PPG Industries, Inc. v. Transamerica Ins. Co. (1999) 20 Cal. 4th 310, Transamerica's insured was sued for compensatory and punitive damages. Transamerica accepted the defense but failed to make reasonable efforts to settle. The insured was held liable for compensatory and punitive damages. Transamerica paid the compensatory damages but denied any liability for the punitives. The insured sued Transamerica for bad faith in failing to settle the case, claiming the insurer's conduct caused the imposition of punitive damages. The Supreme Court held the insurer's conduct in failing to settle was a cause in fact, but not a proximate cause, of the punitive damages. ( PPG Industries, Inc. v. Transamerica Ins. Co., supra, 20 Cal. 4th at p. 315.) The insurer's failure to settle exposed the insured to punitive damages and therefore was a cause in fact. But the court explained that three public policy considerations militated against holding the insurer liable for punitive damages against the insured. The insured's failure to settle was held not to be a proximate cause of the punitive damages. Acknowledging that Transamerica's alleged negligence in failing to settle the lawsuit was a cause in fact of PPG's exposure to liability for punitive damages, the court went on to emphasize that, "To simply say . . . that the defendant's conduct was a necessary antecedent of the injury does not resolve the question of whether the defendant should be liable. . . . The law must impose limitations on liability other than simple causality. These additional limitations are related not only to the degree of connection between the conduct and the injury, but also with public policy." ( PPG Industries, Inc. v. Transamerica Ins. Co., supra, 20 Cal. 4th at pp. 315-316.) The court identified three public policy considerations which militated against imposing liability on Transamerica. Two of them apply here. "First, there is the policy of not allowing liability for intentional wrongdoing to be offset or reduced by the negligence of another." ( PPG v. Transamerica, supra, 20 Cal. 4th at p. 316.)