In the

United States Court of Appeals

For the Seventh Circuit

No. 00-1455

Zurich Insurance Company, doing business

as Zurich American Insurance Company,

Plaintiff-Appellee,

v.

Amcor Sunclipse North America,

Defendant-Appellant.

Appeal from the United States District Court

for the Northern District of Illinois, Eastern Division.

No. 98 C 1152--Rebecca R. Pallmeyer, Judge.

Argued January 17, 2001--Decided February 23, 2001

 Before Easterbrook, Evans, and Williams, Circuit

Judges.

 Easterbrook, Circuit Judge. Sunclipse makes and

sells corrugated paper products. One line, which

it introduced in 1993, is coated with a graphitebased conductive film that protects electronic

components from electrostatic discharge.

Sunclipse initially obtained its coating from

Century Container Corporation under a license

that provided, among other things: "SUNCLIPSE

agrees not to manufacture, distribute or sell any

corrugated box or other container using graphite

liner board purchased from any source other than

CENTURY during the term of this license." While

this license to use Century’s "Centurion"

coatings was still in force, Sunclipse set out to

formulate its own conductive coating, which it

called "Corru-Shield" and began to use late in

1994. Century filed suit, accusing Sunclipse not

only of breaking its promise but also of

misappropriating Century’s trade secrets.

According to Century’s complaint, the

misappropriation took two forms. First, Sunclipse

hired Robert Vermillion as the leader of its

effort to develop its own conductive coating.

Vermillion, according to Century, had learned

some of Century’s trade secrets in December 1993

while seeking employment. Second, Sunclipse sold

its "Corru-Shield" products to customers whose
identities and requirements Century had revealed

as part of the arrangement that gave Sunclipse

access to the "Centurion" coating.

 More than two years after Century launched its

suit, Sunclipse notified Zurich American

Insurance Co., one of its insurers, and asked

Zurich for defense and indemnity. Zurich replied

with this suit under the diversity jurisdiction,

seeking a declaration that the policy does not

cover Century’s claims. (Zurich issued a series

of one-year policies, which are identical in all

important ways. For simplicity, therefore, we

refer to "the policy.") While Zurich’s action was

pending, Sunclipse paid Century $1 million to

settle the underlying suit. It wants Zurich to

reimburse it for this payment, plus the costs of

defense. But the district court granted summary

judgment to Zurich. 85 F. Supp. 2d 842 (N.D. Ill.

2000). It held that California law governs the

dispute and that, as a result, Sunclipse’s delay

does not doom its position. Both sides now accept

these aspects of the decision. The district court

added that the policy does not cover the loss.

This conclusion Sunclipse hotly contests on

appeal.

 The only coverage of the policy relevant to

this case concerns "advertising injury," a term

defined as:

injury arising out of one or more of the

following offenses:

a. Oral or written publication of material that

slanders or libels a person or organization or

disparages a person’s or organization’s goods,

products or services;

b. Oral or written publication of material that

violates a person’s right of privacy;

c. Misappropriation of advertising ideas or

style of doing business; or

d. Infringement of copyright, title or slogan.

This language shows why the district court

granted summary judgment to Zurich. How could

sale of an existing product, to established

customers, cause "advertising injury" just

because the product has a different conductive

coating? The circumstances that made Sunclipse’s

conduct objectionable to Century had nothing to

do with "advertising."

 The policy defines four categories of

advertising injury: defamation, publication of

information that invades a right of privacy,

"[m]isappropriation of advertising ideas or style
of doing business", and "[i]nfringement of

copyright, title or slogan." Sunclipse believes

that misappropriation of customers is the same

thing as misappropriation of advertising ideas

and that any use of a rival’s trade secrets is

"[i]nfringement of . . . title", which has the

same defect. Like most other states, California

construes ambiguities in policies against

insurers, and it requires insurers to put up a

defense against any claim colorably within the

policy. Still, there must first be an ambiguity,

and like the district judge we don’t see one, or

indeed any plausible claim of coverage. The nub

of Century’s claim is that Sunclipse used an

anti-static coating other than Century’s on

products sold to customers Century told it about.

Century did not contend that Sunclipse had

engaged in any kind of promotion other than

person-to-person persuasion. Advertising is a

subset of persuasion and refers to dissemination

of prefabricated promotional material.

Sunclipse’s lawyers submitted an appellate brief

and presented an oral argument in an effort to

persuade three judges, but counsel did not engage

in "advertising," and their disagreement with

Zurich’s lawyers in this court did not

"misappropriate . . . advertising ideas". Nor did

Sunclipse’s use of the "Corru-Shield" coating

"infringe" Century’s copyrights or "title";

Century did not own any of Sunclipse’s products,

and Century certainly did not own the customers.

 Recent years have witnessed a surge of claims

that one or another breach of contract or

business tort that to a normal reader has nothing

to do with advertising nonetheless should be

classified as "advertising injury" under policies

similar to Zurich’s. Interpreting the law of all

three states in this circuit, and of several

others too, we have held that advertising-injury

clauses should be given an ordinary-language

reading, the one the parties likely supposed they

were achieving when negotiating this language.

See, e.g., Western States Insurance Co. v.

Wisconsin Wholesale Tire, Inc., 184 F.3d 699 (7th

Cir. 1999); Erie Insurance Group v. Sear Corp.,

102 F.3d 889 (7th Cir. 1996); Playboy

Enterprises, Inc. v. St. Paul Fire & Marine

Insurance Co., 769 F.2d 425, 428-30 (7th Cir.

1985). Cf. Curtis-Universal, Inc. v. Sheboygan

Emergency Medical Services, Inc., 43 F.3d 1119

(7th Cir. 1994).

 Sunclipse does not deny that, if the law of

Illinois or Indiana or Wisconsin were applied to

this case, then Zurich would prevail. Still,

Sunclipse insists, California has taken a

different road, concluding that even one-on-one

selling efforts constitute "advertising". For

this proposition it relies exclusively on two
decisions of federal district courts, Sentex

Systems, Inc. v. Hartford Accident & Indemnity

Co., 882 F. Supp. 930, 939-40 (C.D. Cal. 1995),

affirmed on other grounds, 93 F.3d 578 (9th Cir.

1996); New Hampshire Insurance Co. v. Foxfire,

Inc., 820 F. Supp. 489, 494 (N.D. Cal. 1993).

These are weak support at best, and not only

because they are federal rather than state

decisions. (Most cases concerning advertising

injury seem to arise between parties of diverse

citizenship, at least one of which prefers

federal court. The resulting paucity of state

decisions has made ascertaining state law

difficult.) The statement in Foxfire is dictum;

the case concerned not a series of one-on-one

solicitations but a letter sent to approximately

30 customers as a group. The district court’s

opinion in Sentex has negligible authority not

only because decisions of district courts lack

precedential (as opposed to persuasive) force,

see Colby v. J.C. Penney Co., 811 F.2d 1119 (7th

Cir. 1987), but also because the court of appeals

went out of its way not to approve the language

on which Sunclipse now relies, deciding the

appeal on other grounds, and later disapproved

some of Sentex’s reasoning expressly. See Simply

Fresh Fruit, Inc. v. Continental Insurance Co.,

84 F.3d 1105, 1108 n.2 (9th Cir. 1996).

 Since Sentex and Foxfire at least one

California decision has implied that individual

solicitations are not advertising. See Peerless

Lighting Corp. v. American Motorists Insurance

Co., 82 Cal. App. 4th 995, 98 Cal. Rptr. 2d 753

(1st Dist. 2000). Sunclipse rightly observes that

Peerless Lighting is not dispositive, because it

dealt with solicitation of a single customer, so

it does not foreclose the possibility that

California would deem a series of similar

solicitations to be "advertising." 98 Cal. Rptr.

at 764 n.11. But although Peerless Lighting does

not scuttle Sunclipse’s position, neither does it

suggest that California will sail a lonely

course, tacking away from the position of other

states on the meaning of "advertising." No case

decided by any state court in California supports

Sunclipse’s position. The best it can say is that

apparently adverse decisions (there are cases in

addition to Peerless Lighting) can be

distinguished. Perhaps so, but that is not enough

for us to conclude, when making a prediction

under Erie about how the Supreme Court of

California would handle this subject, that

California would depart from the normal

understanding of "advertising."

 Nor do we think it likely that California would

treat customer solicitation as "infringement of

title". Once again Zurich has the benefit of the

leading state case on the topic. Palmer v. Truck
Insurance Exchange, 21 Cal. 4th 1109, 988 P.2d

568 (1999), holds that solicitation of customers

whose identity had been learned from another firm

was not "infringement of title" under a policy

similar to Zurich’s. Sunclipse responds that

Palmer dealt with the duty to indemnify rather

than the broader duty to defend, and that the

policies’ language is not identical. The Supreme

Court of California reserved decision on policies

phrased differently, as Zurich’s is. 988 P.2d at

575. True enough, but even if this means that

California law is not conclusively against it,

Sunclipse is bereft of any argument that

California law supports it. Vendors do not have

"title" in their customers, or their custom, so

it would take a bold court indeed to say that a

policy with this language covered solicitation of

customers. "Infringement of . . . title" can’t be

understood without considering "copyright" and

"slogan," the other two words in the coverage

provision. Reading these words together implies

that "infringement" means using someone else’s

words, so that "title" refers to names and

related trademarks, following the pattern of the

phrase "copyright infringement." To rule in

Sunclipse’s favor, a court would have to give

both "infringement" and "title" unusual meanings,

ripping them from the context that is the best

guide to their meaning. No decision that has been

cited to us suggests that California is prepared

to take such liberties with the language.

Affirmed