Armstrong World Industries, Inc. v. Aetna Casualty & Surety Co

In Armstrong World Industries, Inc. v. Aetna Casualty & Surety Co. (1996) 45 Cal.App.4th 1, a corporation, GAF, sought products coverage under its own insurance, but for the products of a company it merged with after the policy period. The Court found no coverage, noting that the insurance company collected premiums based on GAF's sales, and that "unless coverage has been triggered during the policy period, there is no coverage once the policy period has ended. . . . Thus, a corporate acquisition taking place after the policy has expired can have no retroactive effect on the identity of the named insured during the policy period." ( Id. at p. 80.)