In Peerless Lighting Corp. v. American Motorists Ins. Co. (2000) 82 Cal.App.4th 995, the insured was a lighting manufacturer that submitted a bid to another company looking for specialized lighting. To make its bid more acceptable to the company, the insured responded to the company's requirements by submitting a modified sample lighting fixture with its proposal. The sample lighting fixture allegedly was very similar in overall appearance to that of another manufacturer, which sued alleging violations of trademark laws; i.e., infringement of so-called trade dress. The insured tendered its defense to its insurer, which rejected the tender of defense on the ground that the allegations in the complaint did not meet the definition of advertising injury. ( Id. at pp. 1001-1002.) The insured in Peerless was involved in one episode stemming from a single solicitation by one bid with one offending sample product.