The Fourth Circuit Court of Appeals reversed the District Court, holding that under Hawaii law, the insurer had a duty to defend based upon deposition testimony providing facts not found in the underlying complaint. Koppers Performance Chemicals, Inc. v. Argonaut-Midwest Ins. Co., 2024 U.S. App. LEXIS 15678 (4th Cir. June 27, 2024). Our post on the District Court's decision is here.