In Kajima Const. Services, Inc. v. St. Paul Fire and Marine Ins. Co., 2007 WL 4200949 (Ill., 2007), a general contractor (Kajima) and its primary liability insurer (Tokio) filed a declaratory judgment action against a subcontractor's (Midwestern) insurer (St. Paul), which had issued both primary and excess umbrella coverages to Midwestern.

As part of Kajima's and Midwestern's construction contract, Midwestern was required to obtain commercial general liability coverage with Kajima named as an additional insured. Midwestern therefore provided Kajima with a certificate of insurance from St. Paul naming Kajima as an additional insured and providing Kajima with $2 million in general liability coverage and $5 million in umbrella coverage. Kajima also had its own primary CGL insurance policy with Tokio with limits of $1 million per occurrence.