Law360, New York ( April 5, 2016, 11:58 AM EDT) -- Applying New York law, the United States Court of Appeals for the Second Circuit recently affirmed a ruling that a letter asserting that a state government "may" bring an enforcement action against the insured if the insured did not "voluntarily" comply with a particular request, is a "demand" within the meaning of an insurance policy. Weaver v. Axis Surplus Insurance Co., No. 14-4180-cv (2d Cir. March 7, 2016). Weaver demonstrates that written requests lacking certain details or couched in somewhat polite language may qualify as written demands constituting "claims" under claims-made insurance policies, although outcomes could differ because a careful examination of policy language is required in each and every case....