International Flavors & Fragrances, Inc. v. Royal Ins. Co. of Am

In International Flavors & Fragrances, Inc. v. Royal Ins. Co. of Am., 46 AD3d 224, 228, 844 NYS2d 257 [1st Dept 2007], the policies similarly defined "an occurrence" to "includ[e] continuous or repeated exposure to substantially the same general harmful conditions" (see 46 AD3d at 228 ["an occurrence" equated with "an accident"]). Like the Court of Appeals in Appalachian, the Appellate Division in International Flavors concluded that the definition of occurrence did not reflect an intent to aggregate the individual claims (id. at 227). The policies contained no language defining occurrence in a manner that grouped incidents (see id. at 232).