Policyholders who are insured under claims made professional liability insurance policies often struggle with the issue as to when they are required to report knowledge of a potential claim to their insurance company. Recently, the United States Court of Appeals for the Sixth Circuit concluded that, under Ohio law, a policyholder need not report every possible or feasible claim, but rather is only obligated to report those claims that were reasonably probable, reasonably likely to happen, or reasonably certain to occur.

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