Even under an occurrence policy, which links coverage to the date of the tort rather than of the suit, an insurer has a strong interest in prompt notice about claims, so that it can investigate or settle them. See Transport Insurance Co. v. A claims-made policy imposes a more rigid notice requirement, because it links coverage to the claim and notice rather than to the injury. Coverage for claims made in a later period requires an additional premium, which Rovell did not pay. The district court's decision effectively required Home to cover more than one year's claims, but for only one year's premium.
Home is bound only for the year's coverage it contracted to supply.
The question at hand is whether Illinois enforces notice requirements in claims-made policies. As far as we can see, it does. 289 Ill. App. No case we have found, and none Adco has cited, invokes public policy to require the underwriter of a claims-made policy to defend or indemnify a claim of which it did not learn until after the policy expired. But propositions so abstract rarely decide concrete cases.