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Courts in seemingly every jurisdiction are facing a wave of insurance coverage litigation arising out of the COVID-19 pandemic which requires them to address the extent to which typical business insurance policies apply (or not) to our decidedly atypical times. With little appellate guidance to date, courts across the country have reached different, and often irreconcilable, results. A series of recent federal court cases in Ohio has put the challenge (for courts, counsel, and parties alike) on full display. Below, we discuss two cases that reached opposite results based on similar facts, and a third that chose to refer the question to the Ohio Supreme Court.