The U.S. District Court for the Northern District of New York found that an insured did not show that it had submitted a claim, and thus the insurer did not deny the claim, in King's Gym Complex, Inc. v. Philadelphia Indemnity Ins. Co., No. 6:05-CV-1591, 2006 WL 1652455 (N.D.N.Y. June 16, 2006).

A windstorm caused damage to King's Athletic Club, which hired a professional loss consultant to assist in filing a claim with its insurer, Philadelphia Indemnity. Philadelphia paid the property loss claim.