In Hameid v. National Fire Insurance of Hartford (2003) 31 Cal.4th 16, the policy did not define advertising, but defined "advertising injury" to include " 'misappropriation of advertising ideas or style of doing business.' " (Id. at p. 22.) Confronting the term "advertising" itself, the Supreme Court adopted the interpretation relied on by the majority of courts in other jurisdictions--that is, "widespread promotional activities usually directed to the public at large." (Id. at p. 24) This definition comported with the commonly understood sense of the word "advertising." It precluded personal solicitations of individual customers, the basis of the underlying plaintiff's lawsuit.