In Tower Ins Co v. Lin Hsin Long Co., 50 A.D.3d 305, 855 NYS2d 75 [1st Dept 2008] the First Department determined that the injured plaintiff failed to exercise due diligence in attempting to ascertain the identity of the insurer. Like this case, two letters were sent to the insured requesting that the insured's carrier be contacted. The Court found that the letters were insufficient to raise a triable issue of fact as to whether due diligence was exercised. The Court noted that the injured plaintiff never asked the insured for the carrier's name (although, as the dissent noted, there is no indication that the information would have been provided), nor undertook additional, unspecified, efforts to identify the carrier. Other than moving in discovery for the identity of the carrier, this court is unclear as to what those efforts could be, where the insured has decided to ignore a injured plaintiff.