Baker

More than 40 years ago, our state Supreme Court was called upon in Insurance Co. of North America v. Electronic Purification Co. (1967) 67 Cal.2d 679 [ 63 Cal.Rptr. 382 , 433 P.2d 174 ] (Electronic Purification) to interpret a commercial general liability insurance (CGL) policy with a “products hazard” exclusion for bodily injury damages which included both “products” and “completed operations” language. Reading the language and formatting of the policy which had been placed before it in Electronic Purification, the Supreme Court ruled that the “products” and “completed operations” language in the policy exclusion were related, compelling the interpretation that the exclusion applied only to completed operations involving a product, and not to an insured’s business activities that involved only services. In short, the Supreme Court concluded that the policy did not exclude coverage for a claim arising from the insured’s rendition of a service which was only “remotely related to a product.” (Id. at p. 691.)

In the case before us today, we are called upon to interpret a CGL insurance policy which also includes an exclusion of coverage for bodily injury damages caused by…