couple of other allegations that i think vera is typically they argue that the gist of the complaint is about the transfer of the phone lines the transfer of the equipment the duty to defend doesn't concern itself with what the that's an allegation that follows after they've talked about the fact that critic tom i b c was allegedly providing monitoring services up through february of two thousand and two they do alleged that king a different entity provided inferior monitoring management well let me call your attention to excerpt of record pitch sixty five which is also part of the complaint to chick fil a paragraph you read from does say that they're seeking damages based on the transfer of once but page sixty five let me ask you this how is let's take for a moment your much for the specific example of your among other things as this is selling clubs lines to canning or selling any of the others lines became are you alleging that somehow that was negligent how was that while performing any services normal to the business of the insured professional services is a different type of coverage provided than the same policy that's coverage that is limited to the services provided or phone lines are transferred from one end you to another customers come and go all the time those customers and all phone lines there's a there's a and it is a normal part of the alarm monitoring business to transfer phone lines from one person to that transfer of home lines pursuant to a sale is part of the operation of the business i think that it can be part of the normal business but i do think just burns on your suggestion that inferior monitoring services is nowhere found in this complaint and it's found in the complaint is part of the history of  defined term it's defined as any negligent act error or omission while performing any service is normal to the business of the insurer that's that's the seventy three seventy three this is in the eagle protection complaint but before i go to paragraph six this is after you've got allegations that my point was providing your client having sold the business is still on the hook for negligent performance or nonperformance of the contractual obligations then the argument is well having transferred the phone lines to the new person to king the one given back that's negligent is that that's the argument i think there's i think what i mean are you saying that the fact that came doesn't provide very good services is is part of this complaint about the potential coverage is that they can discount liable for providing negligent monitoring services to these plaintiffs resulting in damage to those fighters that  successor in interest is performing negligently and this seems to be true because that's why these people are trying to withdraw from them but you're saying that didn't the negligent failure to respond timely or whatever it is which clearly would be covered had and then your client all the other people are saying hey we want out of here that's correct but when you go to work pretty hard to find in the complaint that there's a continuing obligation your client after say looking i don't think you have to work very hard to find an independent of the sale of home i'm no longer talking about the talked about whether this complaint is on all fours with the coverage terms frankly i can't imagine a situation where a single allegation in a complaint more precisely matches the coverage granted then the allegations in paragraphs have a contract under which you are obliged to provide monitoring services and you drop to us recalls and the house burns down because you know your employee lessly it was sleeping or the  then is whether or not we sufficiently allege that your client is a continuing continuing obligation after transfer of the business to king but whether or not there's negligence the doesn't mention that is among other things selling the phone lines that have among other things failure complaints that are basically unintelligible it's not our responsibility that there are ambiguity in this complaint as to what among other things means but it is clear and it is clear that there is a reference to inferior monitoring services being provided ever time of the sale that from your client to king i don't believe that's in the record i don't and i honestly don't know the answer whether they were told in late one nine hundred ninety nine or whether they were told at some later time when they figure when they finally say i want out inferior monitoring services because damages if they sold the business well the complaint or the policy here requires scottsdale to defend even if the claim is frivolous fraudulent them baseless specifically serves as much that they're required to defend even worse frivolous and fraudulent so even if ultimately it's true that there's no basis to hold critics of liable for the provision of those monitoring services they're required to defend if that is of issue potentially raised by this complaint and i think that it fairly is aside from the allegations which i think really do very closely track the coverage granted that you know policy we offered  that you can articulate orally that you don't have documents for answer only eleven months of my interruption of my business caused by this fiasco he goes on to say i have to be on call to field calls from my customers and instruct king central on how to operate the systems question because king central wasn't giving you very good service yes or king central was enough that is extreme scavenges but one of the plaintiffs in this case what i asked about his good morning i'll be quick there's only alligator alley scottsville there's only one wrongful act alleged in this complaint and that is that they sold phone lines that belong to other people and they pocketed the money and then when they were sued they asked the insurance company basically the say now you take care of it we get to keep the money in effect is what they said the fact of the matter is you look at these allegations and they're talking about selling property owned by someone else and that's the money that they're seeking that's not covered under the arizona mission it is and there is a measure first to performance of services normal to the business it's none of those things it's not performance of anything i almost identical they're drafted by the same firm has the same attorney on on all of these and the only differences i can find is the timing in which they each fired can frankly they may have fired king because king provided enough services that's fine but that's not  critic com for that's when they realized when they fired king that critic com had sold their phone lines and so now they're suing critic com for selling their phone lines that's what this complaint is about and the allegations about ken providing providing service was just that's just how they they found out that they'd been tricked was there ever any allegation i'm not talking just talking about the plane but  before monitoring services that kink negligently performs there's nothing else in the record at all about the critic com lawsuit besides the complaint that what they put into evidence extrinsically is evidence from the king lawsuit insured king and they were suing me for any of services fine of course that's covered so and him back something i think we agree on but i want to make sure that if this were a lawsuit against he has exactly the same policy with you than you in fact have this kind of king starts dropping client calls and other a lot of even though it's a breach of contract would it be negligence within the meaning of your insurance contract oh sure you know it doesn't matter how you frame the cause of action we look at the facts and by the way the thanks for reminding me only issue then really is whether or not it's fairly within this complaint that could have come have a continuing obligation to provide services even after sold hang in the cans defaults are risk of full yeah that's like the there's there's no way to read this and i went this way back as to ritchie and said it was plainly false to claim it can be read that way and and with respect to this paragraph six that we've heard discussion about talking about an agreement to provide monitoring services that was just the nature