In General Accident Insurance Co. v. Superior Court, 55 Cal. App. 4th 1444, 64 Cal. Rptr. 2d 781, 782 (Cal. Ct. App. 1997), Western MacArthur Co. sought declaratory relief against three insurance companies to determine their duties to defend and indemnify it for personal injury actions arising from its predecessor's distribution of asbestos. Pursuant to the product-line successor liability rule, Western MacArthur was found liable for its predecessor's defective products. Because it was not a named insured, Western MacArthur claimed a right to its predecessor's insurance coverage by operation of law. The California Court of Appeals concluded that a finding of successor liability in tort did "not create from whole cloth an insurance relationship between strangers, and insurance coverage under these circumstances does not transfer by operation of law." Id. The court rejected the conclusion of Northern Insurance Co. v. Allied Mutual Insurance Co., 955 F.2d 1353 (9th Cir. 1992), cert. denied, 505 U.S. 1221, 120 L. Ed. 2d 903, 112 S. Ct. 3033 (1992) that insurance coverage transfers by operation of law by a finding of successor liability for product liability torts. "An insured-insurer relationship is a matter of contract. Successor liability is a matter of tort duty and liability. It is one thing to deem the successor corporation liable for the predecessor's torts; it is quite another to deem the successor corporation a party to insurance contracts it never signed, and for which it never paid a premium, and to deem the insurer to be in a contractual relationship with a stranger." (General Accident, 64 Cal. Rptr. 2d at 785.) The court concluded that the product-line successor liability rule is a narrow exception to the rule against successor liability, that the rule should not be extended to insurance coverage cases, that coverage is a question of contract interpretation, that the duty to defend is based on the subject insurance contract, and that the person injured in a successor liability case is not in a contractual relationship with the manufacturer and "generally cannot protect himself or herself from the eventuality of injury from a product manufactured by a predecessor company." 64 Cal. Rptr. 2d at 786.