In Boicourt v. Amex Assurance Co. (2000) 78 Cal.App.4th 1390, the insurer had a blanket rule against disclosing its policy limits to a claimant before litigation. The court concluded such a rule "creates a conflict of interest between liability insurers and their insureds," giving the insurer "a tactical advantage vis--vis the claimant by forcing the claimant to make any prelitigation offers 'in the dark.'" (Id. at p. 1392.) Boicourt thus reversed a grant of summary judgment to the insurer that was based on "the idea that there could be no conflict of interest absent a formal settlement offer." (Ibid.) Noting the relevance of disclosure of policy limits to the settlement of a claim, and the potential "real world effect of 'foreclosing' the possibility of a quick settlement within policy limits" (id. at pp. 1393, 1397), Boicourt concluded: "In short, insurers do have a 'selfish' interest (that is, one that is peculiar to themselves) in imposing a blanket rule which effectively precludes disclosure of policy limits, and that interest can adversely affect the possibility that an excess claim against a policyholder might be settled within policy limits. Thus, a palpable conflict of interest exists in at least one context where there is no formal settlement offer. We therefore conclude that a formal settlement offer is not an absolute prerequisite to a bad faith action in the wake of an excess verdict when the claimant makes a request for policy limits and the insurer refuses to contact the policyholder about the request." (Id. at pp. 1398-1399; see id. at p. 1399 "the claimant's request for the policy limits might have been a settlement opportunity which was arbitrarily foreclosed by the insurer for its own advantages to the insured's detriment".) The Court held that an insurer's blanket policy of refusing to disclose policy limits in advance of litigation may give rise to a bad faith claim. (Id. at p. 1392.) The Boicourt court reasoned that "a liability insurer ' "is playing with fire" ' when it refuses to disclose policy limits. Such a refusal ' "cuts off the possibility of receiving an offer within the policy limits" ' by the company's ' "refusal to open the door to reasonable negotiations." ' " (Ibid.) In Boicourt, the appellate court reversed a summary judgment "based on the idea that there could be no conflict of interest absent a formal settlement offer" concluding instead that a conflict of interest between insurer and insured could arise even absent a formal settlement offer. (Ibid.)