CALIFORNIA'S UNFAIR COMPETITION LAW, COVID COVERAGE, AND IMPLIED COVENANT BREACH.

With reference to California's Unfair Competition Law specifically, it may be "that allegations sufficient to support a cause of action for breach of the covenant of good faith and fair dealing are also sufficient to support a claim for violation of the UCL."  Shusha, Inc. v. Century-Nat'l Ins. Co., 87 Cal. App. 5th 250, 303 Cal. Rptr. 3d 100, 114 n. 11 (Cal. 2d DCA, Div. 7 2022) (COVID insurance coverage case involving a commercial policy for lost business income; Century-National did not dispute that possibility in this case), review granted, 307 Cal. Rptr. 3d 1, 527 P.3d 271 (2023).

Express Statutory Causes of Action in first-party cases in the United States are discussed in Section 9:14 of 2 DENNIS J. WALL, LITIGATION AND PREVENTION OF INSURER BAD FAITH (West Publishing Company 3d Edition, 2023 Supplements in process).

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