In Atlantic Mutual Ins. Co. v. J. Lamb, Inc. (2002) 100 Cal.App.4th 1017, the court considered a trade libel claim in the context of a dispute concerning an insurer's duty to defend. The court found statements charging a claimant with unlawfully violating defendant's patents disparaging to both the claimant itself and its products. (Id. at pp. 1034-1035.) The court reasoned that the statements "amounted to a denigration of claimant's products" because they "clearly stated that claimant's products were burdened with a legal infirmity that would place a customer in legal jeopardy if it purchased and used or resold the product." (Id. at p. 1037.)