In the Dynamic Concepts, Inc., case, the issue was "whether an insurer in an action involving covered and uncovered claims is automatically obliged to provide independent counsel pursuant to Civil Code section 2860, subdivision (b)." ( Dynamic Concepts, Inc. v. Truck Ins. Exchange, supra, 61 Cal. App. 4th at p. 1006.) The insured under a comprehensive general liability policy was sued for breach of contract, fraud, interference with prospective economic advantage, RICO (Racketeer Influenced and Corrupt Organizations Act) and declaratory relief, as well as for conversion. There was a final cause of action for trade libel. Truck Insurance Exchange accepted the tender of defense, invoked by the libel claim, under a reservation of rights since none of the other claims was covered under the policy. In rejecting a per se rule requiring appointment of independent counsel whenever there is a "global reservation of rights" (Dynamic Concepts, at p. 1007), Dynamic Concepts stated that "no reason exists to allow insureds who face the prospect of no defense or indemnity for uncovered claims to 'set up' insurers by making Cumis demands with unreasonably short deadlines, especially where the issues listed in the underlying litigation do not coincide with the issues raised in the reservation of rights and where the insurer agrees to provide a full and complete defense without regard to coverage. An insurer's reservation of rights may create a disqualifying conflict of interest requiring the insurer to pay the cost of Cumis counsel to represent the insured in the underlying action. But not every reservation of rights entitles an insured to select Cumis counsel. There is no such entitlement, for example, where the coverage issue is independent of, or extrinsic to, the issues in the underlying action [citations]." ( Id. at p. 1006.) The court found that "The supposed Cumis conflict for the covered libel claim was vague, ephemeral and highly theoretical." (Id. at pp. 1009-1010.) There is no talismanic rule that allows a facile determination of whether a disqualifying conflict of interest exists. Instead, "The potential for conflict requires a careful analysis of the parties' respective interests to determine whether they can be reconciled . . . or whether an actual conflict of interest precludes insurer-appointed defense counsel from presenting a quality defense for the insured." (Dynamic Concepts, Inc. v. Truck Ins. Exchange, supra, 61 Cal. App. 4th at pp. 1007-1008.) "Insurer appointed defense counsel may obviate any potential conflict involving uncovered claims by ' "proceed[ing] diligently to litigate the matters that he was charged with on behalf of his client [the insured]." ' " ( Id. at p. 1008, original italics.) In Native Sun Investment Group v. Ticor Title Ins. Co. (1987) 189 Cal. App. 3d 1265 [235 Cal. Rptr. 34], the state asserted claims against the plaintiff's property, some of which the insurer conceded were covered and some of which it denied. In finding no conflict requiring appointment of Cumis counsel because there was no limitation placed by the insurer on the litigation of any of the claims, covered or uncovered, and counsel showed no preference in his defense of the suit, the court noted that a key to determining whether a disqualifying conflict exists is whether "the retained attorney in fact was . . . subject to the conflicting forces which gave rise to Cumis . . . ." (Id. at pp. 1277-1278, italics added.) A disqualifying conflict exists if "Insurance counsel had . . . incentive to attach liability to [the insured]." ( Blanchard v. State Farm Fire & Casualty Co., supra, 2 Cal. App. 4th at p. 350.) "The test is whether the conflict 'precludes the insurer-appointed defense counsel from presenting a quality defense for the insured.' " (Croskey et al., Cal. Practice Guide: Insurance Litigation (The Rutter Group 1999) P 7:772.)