Insurance Law Alert

November 2022

In This Issue
Loss Of Use Of Computer Servers Is Not Direct Physical Loss, Says Ohio
District Court
An Ohio district court ruled that an insured’s loss of use of computer servers from a thirdparty vendor did not give rise to coverage under a property policy. Computer Programming
Unlimited, Inc. v. Hartford Cas. Ins. Co., No. 3:21-CV-2350 (N.D. Ohio Oct. 26, 2022).
(Click here for full article)“They aretremendous
writers and do a great
job collaborating withco-counsel. They understandand are dedicated to theindustry.”– The Legal 500(quoting a client)

Kentucky Supreme Court Rules That Government Subpoena Does Not
Trigger Policy’s Prior Notice Exclusion
The Kentucky Supreme Court ruled that the policyholder’s tender of a government subpoena to
its D&O insurer a few years before it was named as a defendant in civil litigation did not triggera prior notice exclusion in a professional liability policy. Ashland Hospital Corp. v. Darwin
Select Ins. Co., 2022 WL 12198051 (Ky. Oct. 20, 2022). (Click here for full article)

Claims Based On Insurer’s Alleged Disclosure Of Personal Identifying
Information May Proceed, Says New York District Court
A New York district court denied in part an insurer’s motion to dismiss claims stemming fromthe alleged disclosure of plaintiffs’ personal identifying information to cybercriminals. Rand v.
Travelers Indem. Co., 2022 WL 15523722 (S.D.N.Y. Oct. 26, 2022). (Click here for full article)

Minnesota Court Rules That Email Hacking Scheme Losses Are Covered
Under Cyber Business Interruption Provision
A Minnesota district court granted a policyholder’s summary judgment motion, ruling thatlosses stemming from a hacking scheme that allowed a bad actor to intercept and impersonate
emails relating to invoice payments were covered under a Technology Professional Liability
Policy. Fishbowl Solutions, Inc. v. Hanover Ins. Co., 2022 WL 16699749 (D. Minn. Nov. 3,2022). (Click here for full article)

Sixth Circuit Rules That Dispute Over Limitation Period In Reinsurance
Contract Is Question For Arbitrator, Not Court
The Sixth Circuit ruled that the question of whether a three-year limitation in a reinsurance
agreement precluded arbitration was a question for the arbitrator, not the court. Alliance
Health and Life Ins. Co. v. American National Ins. Co., 2022 WL 2903440 (6th Cir. July 22,2022). (Click here for full article)

Simpson Thacher & Bartlett LLP

1

Oregon Court Allocates Defense And Indemnity Costs On Pro Rata Basis
An Oregon district court ruled that defense costs must be allocated among insurers based ontime on the risk and that indemnity costs must be allocated according to statutory law, which
contemplates pro rata time on the risk and policy limits. National Surety Corp. v. TIG Ins. Co.,
2022 WL 16694733 (D. Ore. Nov. 2, 2022). (Click here for full article)

Two Recent Decisions Highlight Parameters Of Broker Liability For
Negligent Procurement Of Insurance
The Eighth Circuit affirmed the dismissal of negligence claims against an insurance agent,
whereas a California jury concluded that an agent was professionally negligent in failing toprocure insurance. I Square Management, LLC v. McGriff Ins. Svs., Inc., 2022 WL 16828847(8th Cir. Nov. 9, 2022); Daniels v. Samrick, No. 18 CV 001467 (Cal. Super. Ct. Oct. 17, 2022).
(Click here for full article)

Arizona Supreme Court Rules That Insurer May Not Depreciate Labor
Costs In Calculating Actual Cash Value
The Arizona Supreme Court ruled that labor costs may not be depreciated in calculating actual
cash value for property insurance purposes. Walker v. Auto-Owners Ins. Co., 254 Ariz. 17(2022). (Click here for full article)

STB News Alerts
Click here to learn more about the Firm’s insurance-related honors, publications andengagements.

2

Coverage Alerts:
Loss Of Use Of Computer Servers
Is Not Direct Physical Loss, Says
Ohio District Court
An Ohio district court ruled that an insured’s
loss of use of computer servers from athird-party vendor did not give rise tocoverage under a property policy. Computer
Programming Unlimited, Inc. v. Hartford
Cas. Ins. Co., No. 3:21-CV-2350 (N.D. Ohio
Oct. 26, 2022).
Computer Programming Unlimited (“CPU”),
an information technology service provider,secured server space from Nuvolat Cloud.
When Nuvolat notified CPU that it was
filing for bankruptcy and unable to continue
providing cloud services, CPU retained areplacement vendor and was able to transfer
its client data without any interruption inservice. Thereafter, CPU sought coverage
from Hartford for losses allegedly incurredin connection with Nuvolat’s default inservices. Hartford denied coverage based on
the absence of direct physical loss or damage,as required by the policy. CPU filed suit andHartford moved for summary judgment.
The court ruled in Hartford’s favor, holdingthat Nuvolat’s inability to continue providing
servers did not constitute physical loss ordamage. The court explained that “loss of use,functionality, and reliability” is insufficientto establish direct physical loss or damage,and in any event, is explicitly excluded
from coverage under the policy. The court
distinguished cases in which a loss of use
resulted from a physical alteration to covered
property and was therefore deemed to bewithin the scope of coverage.

Kentucky Supreme Court Rules
That Government Subpoena Does
Not Trigger Policy’s Prior Notice
Exclusion
The Kentucky Supreme Court ruled thatthe policyholder’s tender of a government
subpoena to its D&O insurer a few years
before it was named as a defendant in civil
litigation did not trigger a prior noticeexclusion in a professional liability policy.
Ashland Hospital Corp. v. Darwin Select Ins.
Co., 2022 WL 12198051 (Ky. Oct. 20, 2022).

In 2011, the Department of Justice (“DOJ”)
served a subpoena duces tecum on a hospital,
seeking files relating to its treatment ofcardiac patients. The hospital’s D&O
insurer agreed to cover the costs incurredin complying with the subpoena. In 2013,
the hospital notified Allied, its professional
liability insurer, of the subpoena andongoing investigation, as well as a litigation
hold letter it received from counsel said torepresent hundreds of potential claimants
against the hospital. Allied argued that those
notifications did not constitute proper “noticeof circumstances that might give rise to aclaim” because they failed to include certain
specific details required under the policy. In
addition, Allied asserted that coverage wasbarred by Exclusion 15, which applied toclaims “based on, arising out of, directly or
indirectly resulting from, or in consequenceof, or in any way involving . . . any facts,
matters, events, suits or demands notified orreported to, or in accordance with, any policyof insurance . . . in effect prior to October 16,
2012.” Allied’s position was that Exclusion 15
applied because the hospital had submitted
the subpoena claim to its D&O insurer in
2011. Nonetheless, Allied agreed to defend
the underlying civil suit under a reservationof rights.
The DOJ investigation ended with asettlement in which the hospital did
not concede liability but agreed to pay
approximately $40 million in fines.
Thereafter, the hospital filed a declaratory
judgment action, seeking a ruling as toits rights under Allied’s policy as well as
an excess policy. A trial court ruled in thehospital’s favor, finding that neither Exclusion
15, nor two other exclusions (relating tointentional acts or government-related
claims) barred coverage. An intermediateappellate court reversed, finding that
Exclusion 15 applied.
The Kentucky Supreme Court reversed. The
court held that Exclusion 15 did not apply
because the subpoena did not constitute3

adequate notice of circumstances giving rise
to a claim in 2011. In particular, the subpoena
failed to specify the “time, date and place”
of the claim or “a description of the injury
or damage which has allegedly resulted.”
The court explained that while subsequent
events that unfolded over the following two
years ultimately indicated that the DOJ
investigation and the civil suit arose from thesame facts and events, that conclusion was
not evident in 2011, when the hospital notified
its D&O insurer of the subpoena. The court
stated:[H]indsight is 20/20. And looking at
this case from the perspective of 2022,
the DOJ inarguably was investigating
facts, matters, and circumstances sharedby the Cardiac Litigation. But in thisinstances, hindsight is obscuring thereasonable interpretation of the language
by a lay reader which sensibly supports
the interpretation that the policy
contemplates a great deal of specificity
to constitute notice of circumstances
giving rise to a claim that is absent fromthe subpoena.
The court acknowledged that in someinstances, notification might require
supplementary communications within areasonable period of time, but rejected “theproposition that notice could be gathered overmultiple years.” As the court emphasized,
Allied itself took the position that that the2011 subpoena did not constitute notice of
circumstances that might give rise to a claim.
In addition, the court reasoned that Allied
created an expectation of coverage by issuingconsecutive policies in subsequent years
even after learning of the ongoing DOJ
investigation without informing the hospitalof its position that Exclusion 15 would bar
coverage under those policies.

Cyber Alerts:
Claims Based On Insurer’s Alleged
Disclosure Of Personal Identifying
Information May Proceed, Says
New York District Court
A New York district court denied in partan insurer’s motion to dismiss claims
stemming from the alleged disclosure ofplaintiffs’ personal identifying information
to cybercriminals. Rand v. Travelers Indem.
Co., 2022 WL 15523722 (S.D.N.Y. Oct.
26, 2022).
A putative class of plaintiffs alleged that theinsurance quote application on Travelers’
website “is easily exploitable by non-parties”
and that unauthorized users obtained
sensitive personal information by improperly
using the credentials of Travelers agents.
Plaintiffs alleged that they spent time andresources detecting and preventing misuseof personal information and that additionalcosts would be incurred in the future in order
to avoid identity theft or fraud. Travelers
moved to dismiss the complaint on several
bases, most of which the court denied.
The court rejected the contention that theplaintiffs did not allege an injury-in-fact
to support Article III standing. The court
explained that a loss of privacy, as well as
the harm incurred in mitigating existing andfuture identity theft, were properly alleged
injuries-in-fact, notwithstanding the absenceof allegations that the personal information
had actually been misused by cybercriminals.
Noting that this was a “close call,” the court
concluded that based on the suspicious
activity of the hackers, as well as the sensitive
nature of the information accessed (name,address, date of birth and driver’s license
number), the complaint adequately pled
an imminent risk of future identity theftand mitigating costs so as to constitutean injury-in-fact.
The court further ruled that the complaint
alleged claims under the Driver’s Privacy
Protection Act, which prohibits entities from“knowingly disclosing or otherwise making
available to any person or entity” personal
information. The court explained that
Travelers could be liable under this statute fora third-party’s impermissible use of personal
information based on its voluntary decision to
auto-populate its quote responses online with4

sensitive personal information. In so ruling,
the court emphasized that two warnings
had been issued by the New York State
Department of Finance as to the vulnerabilityof this website feature.
The court also declined to dismiss negligenceclaims, finding that the complaint alleged aviolation of a duty of care and recoverable
damages. As to damages, the courtemphasized that actual costs incurred inpurchasing credit monitoring and identity
theft services were cognizable expenses, butthat various other current and future costs,
including the time and effort spent addressing
the potential consequences of a data breach or
the mere fact of a lower credit score, were notrecoverable damages.

Minnesota Court Rules That
Email Hacking Scheme Losses Are
Covered Under Cyber Business
Interruption Provision
A Minnesota district court granted apolicyholder’s summary judgment motion,
ruling that losses stemming from a hacking
scheme that allowed a bad actor to intercept
and impersonate emails relating to invoice
payments were covered under a Technology
Professional Liability Policy. Fishbowl
Solutions, Inc. v. Hanover Ins. Co., 2022 WL
16699749 (D. Minn. Nov. 3, 2022).
Fishbowl was the victim of a scheme in whicha bad actor gained access to the email accountof a senior accountant and impersonatedher in communications with clients inorder to provide new payment instructions
for invoices. After discovering the fraud,
Fishbowl sought coverage under a provisionthat stated:
We will pay actual loss of “businessincome” and additional “extra expense”
incurred by you during the “period ofrestoration” directly resulting from a“data breach” which is first discovered
during the “policy period” and which
results in an actual impairment or denialof service of “business operations”
during the “policy period.”
Hanover denied the claim on several bases,
each of which was rejected by the court.
Actual Loss of Business Income: Hanoverargued that there was no loss of “businessincome,” defined as “Net Income . . . thatwould have been earned or incurred if
there had been no impairment or denial of‘business operations.’” Hanover claimed thatbusiness operations refer only to incomegenerating activities and that invoicing
clients does not generate income, and thatFishbowl sought recovery of money alreadyearned, rather than money “that would havebeen earned.” Rejecting these contentions,the court concluded that the policy did not
expressly limit business operations to incomegenerating activities and that the diversionof invoice payments was income that “would
have been earned” (rather than income that
was already earned) notwithstanding thatthe work for those invoices had already been
performed.
Directly Resulting From Data Breach: While
Hanover conceded that Fishbowl experienced
a data breach, it argued that the loss did
not result directly from that breach. Rather,
Hanover claimed that the loss resulted fromintervening causes, including the negligenceof the customer that remitted payment tothe bad actor without noticing warning
signs about potential fraud. Noting the lackof evidence of such negligence, the court
declined to find such “intervening agency”
and ruled that Fishbowl’s losses “would nothave occurred without the bad actor accessing
Ms. Williams’s email and sending fraudulent
communications.”
Impairment of Business Operations: Hanoverargued that there was no impairment
or interruption of Fishbowl’s business
operations because it continued to conduct
its normal income-generating activities evenduring the period of email hacking. Rejecting
this assertion, the court held that the term
“impairment” is sufficiently broad so as toencompass the hacker’s interference withthe accountant’s email and does not require5

a business to cease functioning entirely.
The court noted that while the provision
includes the word “Interruption” in its title,
use of the word “impairment” within the
text of the provision indicates that the policy“specifically grants coverage when a businesssuffers something less than a total suspensionof operations.”

established case law. The court notedthat parties may contract around such a
presumption, but that the reinsurance
agreement at issue contained no language
indicating an intent to assign the time limit
issue to a judge rather than an arbitration
panel. Further, the court emphasized thatthe broad language in the arbitration clausesupported its conclusion.

Arbitration Alert:
Sixth Circuit Rules That Dispute
Over Limitation Period In
Reinsurance Contract Is Question
For Arbitrator, Not Court
Affirming a Michigan district court decision,
the Sixth Circuit ruled that the questionof whether a three-year limitation in a
reinsurance agreement precluded arbitration
was a question for the arbitrator, not the
court. Alliance Health and Life Ins. Co.
v. American National Ins. Co., 2022 WL
2903440 (6th Cir. July 22, 2022).
A reinsurance agreement between American
National and Alliance Health included anarbitration provision that provided: “Asa precedent to any right of action under
this Agreement, if any dispute shall arise. . . with reference to the interpretationof the Agreement or [the parties’] rights
with respect to any transaction involved,
whether such disputes arise before or aftertermination of this Agreement, such dispute,
upon the written request of either party,
shall be submitted to three arbitrators.” Theagreement further stated that “[n]o arbitration
may be commenced more than 3 years after
the Effective Date of this Agreement.” When
American National rejected a reinsurance
claim, Alliance Health sued in federal court.
American National moved to dismiss on
the ground that the dispute was subject toarbitration. In response, Alliance Healthargued that because the claim was outside theagreement’s three-year limit for commencing
arbitration, it could proceed in court. The
district court rejected this contention, rulingthat the question of whether the time limit
applied was for an arbitrator to decide. The
Sixth Circuit affirmed.

Allocation Alert:

The Sixth Circuit explained that application of
the agreement’s time limit “is a quintessential
question of procedural arbitrability” under

The court held that the statute, which refers
to allocation of “covered damages,” applies
only to indemnity costs, and not to defense

Oregon Court Allocates Defense
And Indemnity Costs On Pro Rata
Basis
An Oregon district court ruled that defense
costs must be allocated among insurers basedon time on the risk and that indemnity costs
must be allocated according to statutory law,which contemplates pro rata time on the risk
and policy limits. National Surety Corp. v.
TIG Ins. Co., 2022 WL 16694733 (D. Ore.
Nov. 2, 2022).
In this contribution action, National Surety
sought a declaration that TIG Insurance
issued general liability policies in certain
years and was therefore required to pay its
share of defense and indemnity costs for amutual insured in underlying environmental
pollution litigation. Oregon statutory law
provides such a right to contribution and sets
forth a list of factors to consider in allocation,
including each insurer’s time on the risk andpolicy limits, among other things. See O.R.S.
464.480(5).

6costs. The court further concluded thatthe most equitable method of allocating
defense costs was time on the risk, themethod endorsed by the majority of district
courts in Oregon and in other jurisdictions
addressing the allocation of defense costs
between consecutive insurers in the context ofenvironmental claims. In so ruling, the court
noted that time on the risk allocation aligns
insurers’ expectations of defense costs withthe proportion of risk they assumed basedon the duration of their coverage period incomparison to the overall period of damage or
injury.
With respect to indemnity costs, the court
applied the factors set forth in O.R.S.
465.480(5) and endorsed a method that
allocated costs based on the average of each
insurer’s pro rata time on the risk (i.e., thepercentage of time the policy was in effectas compared to the total period of damage)and its policy limits (i.e., the percentage ofthe policy limit of the particular policy ascompared to the overall insurance limits
during the total period of damage).

Broker Alert:
Two Recent Decisions Highlight
Parameters Of Broker Liability
For Negligent Procurement Of
Insurance
The Eighth Circuit affirmed the dismissal ofnegligence claims against an insurance agent,
whereas a California jury concluded that an
agent was professionally negligent in failing toprocure insurance.

In I Square Management, LLC v. McGriff
Ins. Svs., Inc., 2022 WL 16828847 (8thCir. Nov. 9, 2022), policyholders sued theirinsurance agent for negligence after learningthat their policy did not cover flood-related
losses. The policyholders alleged that theiragent advised them that a builder’s risk policy
was unnecessary for a construction project,which resulted in the absence of coveragefor damage to certain property stored in awarehouse.
Applying Arkansas law, the court explainedthat as a general matter, the duty is on theinsured to obtain the coverage needed andthat an insurance agent is under no duty
to provide information about additional
coverage. The court noted that while somejurisdictions have imposed a duty on theagent to advise a client of appropriate
coverage where a “special relationship”
exists between the parties, it concluded that
Arkansas was unlikely to adopt such an
exception, and if it did, would apply it very
narrowly in rare situations. More specifically,
the court explained that neither the insured’s
reliance on the agent’s expertise nor theagent’s representations of skill and knowledge
created a special relationship, stating that “itwould be the rare agent who does not holdhimself out as highly skilled, and the rare
insured who doesn’t rely on the agent’s skill inmaking insurance selections.” The court also
deemed it irrelevant that the agent engaged
in a personalized pitch to the insureds, which
resulted in them abandoning their prior agent
and hiring the current agent. Similarly, thecourt was not persuaded that the agent’s
communications with various participants inthe construction project established a special
relationship, noting that the communications

7were “isolated and infrequent” and thatthe agent’s involvement in the project
was tangential. Finally, the court rejected
the contention that the agent voluntarily
assumed a duty to ensure adequate coverage,emphasizing that a single email indicatingthat a builder’s risk policy was unnecessary
did not constitute an assumption of anadditional duty of care.
In contrast, a jury awarded a policyholder
more than $4 million in damages after findingthat an insurance agent was professionally
negligent in Daniels v. Samrick, No. 18
CV 001467 (Cal. Super. Ct. Oct. 17, 2022).
After a fire destroyed insured property, thepolicyholders sued their agent for professional
negligence, negligent misrepresentation
and breach of fiduciary duty, alleging thatthe agent failed to comply with their specificrequests to increase coverage limits. In
support of their claims, the policyholders
pointed to the agent’s representations andwarranties about expertise, as well as thelong standing relationship and course of
dealings for decades. After a three week
trial, the jury found that the agent wasprofessionally negligent and that thenegligence was a substantial factor in causing
harm to the policyholders. However, thejury also concluded that the policyholders
were partially responsible based on theirnegligence in obtaining the coverage
they wanted.

An Arizona district court certified twoquestions to the Arizona Supreme Court:(1) When a homeowner’s insurance
policy does not define the terms “actual
cash value” or “depreciation,” may aninsurer depreciate the costs of bothmaterials and labor in determining theactual cash value of a covered loss?
(2) Is the broad evidence rule applicablein Arizona such that an insurer and/or fact finder may consider labor
depreciation as a pertinent factor in
determining actual cash value?
The Arizona Supreme Court answered bothquestions in the negative with respect tothe policy at issue. The court noted thatthe highest courts in Illinois, Tennessee,
Arkansas and Mississippi have not permitted
the depreciation of labor costs in calculating
ACV and emphasized that under Arizona law,
an insurer seeking to limit its liability undera policy must “clearly and distinctly” do sothrough policy language. With respect to thebroad evidence rule, the court held that while
the rule was not applicable in the present
case, it could potentially apply in interpretingother property policies.

Property
Insurance Alert:
Arizona Supreme Court Rules That
Insurer May Not Depreciate Labor
Costs In Calculating Actual CashValue
As discussed in previous Alerts, several statesupreme courts and federal appellate courts
have addressed whether an insurer may
depreciate labor costs in calculating actual
cash value (“ACV”). See May and October
2021 Alerts; March and April 2020 Alerts;
April 2019 Alert; March 2017 Alert; January
and February 2016 Alerts. The ArizonaSupreme Court recently weighed in, rulingthat labor costs may not be depreciated in the
ACV calculation. Walker v. Auto-Owners Ins.
Co., 254 Ariz. 17 (2022).
8

STB News Alerts
Joshua Polster and Laurel Fresquez authored“Insurance Ruling Provides Lessons On
Cyberattack ‘Twofers,’” published by Law360.
The article examines a recent Minnesota
district court decision analyzing insurance
coverage for a cyberattack involving hacking
and social engineering components under two
distinct policy provisions with separate limits.
Summer Craig participated in the Practicing
Law Institute’s “Property and Casualty
Insurance Law 2022” program on October
27th in New York. Summer spoke on a panel
titled “Environmental Insurance: Business
Interruption Coverage and Claims,” which
included discussion of policy provisions
addressing both first-party and third-party

claims. The panelists explained how tointerpret business interruption coverage
language in connection with “communicabledisease” coverage claims; how to prepareor review potential COVID-19 claims underpollution policies; and how to evaluate
coverage issues arising from PFAS, among
other items.
Lynn Neuner was named a 2022 “Litigation
Trailblazer” by The National Law Journal.
Lynn was recognized for her work in ongoing
litigation over a Ponzi scheme perpetrated
by Robert Allen Stanford, as well as for wins
secured on behalf of clients in insurance
coverage litigation and securities classactions, and her longstanding advocacy onbehalf of veterans.

9Simpson Thacher has been an international leader in the practice of insurance and reinsurance law for
more than a quarter of a century. Our insurance litigation team practices worldwide.

Mary Beth Forshaw+1-212-455-2846
mforshaw@stblaw.com

Lynn K. Neuner+1-212-455-2696
lneuner@stblaw.com

Sarah E. Phillips+1-212-455-2891
sarah.phillips@stblaw.com

Andrew T. Frankel+1-212-455-3073
afrankel@stblaw.com

Joshua Polster+1-212-455-2266
joshua.polster@stblaw.com

Isaac M. Rethy+1-212-455-3869
irethy@stblaw.com

Bryce L. Friedman+1-212-455-2235
bfriedman@stblaw.com

Tyler B. Robinson+44-(0)20-7275-6118
trobinson@stblaw.com

Abigail W. Williams+1-202-636-5569
abigail.williams@stblaw.com

Michael J. Garvey+1-212-455-7358
mgarvey@stblaw.com

George S. Wang
+1-212-455-2228
gwang@stblaw.com

Chet A. Kronenberg+1-310-407-7557
ckronenberg@stblaw.com

Summer Craig+1-212-455-3881
scraig@stblaw.com

This edition of the
Insurance Law Alert was prepared byBryce L. Friedman / +1-212-455-2235
bfriedman@stblaw.com andChet A. Kronenberg / +1-310-407-7557
ckronenberg@stblaw.com
with contributions by Karen Cestarikcestari@stblaw.com.

The contents of this publication are for informational purposes only. Neither this publication nor the
lawyers who authored it are rendering legal or other professional advice or opinions on specific facts
or matters, nor does the distribution of this publication to any person constitute the establishment of an
attorney-client relationship. Simpson Thacher & Bartlett LLP assumes no liability in connection withthe use of this publication. Please contact your relationship partner if we can be of assistance regardingthese important developments. The names and office locations of all of our partners, as well as ourrecent memoranda, can be obtained from our website, www.simpsonthacher.com.
Please click here to subscribe to the Insurance Law Alert.
10SimpsonThacherWorldwide

UNITED STATESEUROPEASIANew York
425 Lexington Avenue
New York, NY 10017+1-212-455-2000

Brussels
Square de Meeus 1, Floor 7
B-1000 Brussels
Belgium+32-472-99-42-26

Beijing
3901 China World Tower A
1 Jian Guo Men Wai Avenue
Beijing 100004
China+86-10-5965-2999

Houston
600 Travis Street, Suite 5400
Houston, TX 77002+1-713-821-5650
Los Angeles
1999 Avenue of the Stars
Los Angeles, CA 90067+1-310-407-7500
Palo Alto
2475 Hanover Street
Palo Alto, CA 94304+1-650-251-5000
Washington, D.C.
900 G Street, NW
Washington, D.C. 20001+1-202-636-5500

LondonCityPoint
One Ropemaker Street
London EC2Y 9HUEngland+44-(0)20-7275-6500

Hong Kong
ICBC Tower
3 Garden Road, Central
Hong Kong+852-2514-7600
Tokyo
Ark Hills Sengokuyama Mori Tower
9-10, Roppongi 1-Chome
Minato-Ku, Tokyo 106-0032
Japan+81-3-5562-6200

SOUTH AMERICA

São Paulo
Av. Presidente Juscelino
Kubitschek, 1455
São Paulo, SP 04543-011
Brazil+55-11-3546-1000

11