Hayward

facts, there is “any potential for liability under the policy.” Horace Mann Ins. Co. v. Barbara B., 846 P.2d 792, 795, 797 (Cal. 1993). Coverage for advertising injury requires the pol- icy holder to offer facts to support a finding of: (1) an adver- tising injury as defined in the policy, (2) a course of advertising, and (3) proof of a causal relationship between the first and second elements. Bank of the West v. Superior Court, 833 P.2d 545, 558-60 (Cal. 1992). Centennial and Hayward dispute the first element: whether the In Sync complaint raised issues potentially within the advertising injury cover- age under the insurance policy. 15724 HAYWARD v. CENTENNIAL INSURANCE CO. [2] Under Hameid,1 advertising injury “requires widespread promotion to the public such that one-on-one solicitation of a few customers does not give rise to the insurer’s duty to defend the underlying lawsuit.” Hameid, 71 P.3d at 762. In Hameid, beauty salon workers and their new employer (Hameid) were sued by the workers’ former employer, a neighboring salon owner, for utilizing plaintiff’s customer list to identify and solicit customers. Id. at 763, 765. The com- plaint alleged the “defendants…