3M cites no authority for the proposition that, before the earnings were distributed, 3M had the right to possess those earnings or exercise any of the other traditional attributes of ownership over those earnings. 3M also cites Sears Roebuck & Co. v. National Union Fire Insurance Co. of Pittsburgh, Pa, No. B187280, 2007 WL 2876149 (Cal. Ct. App. Oct. 4, 2007) for the proposition that courts interpret the "ownership" provision broadly. But Sears Roebuck looked to state law to determine whether the insured had an ownership interest in the stolen funds, id. at *4-6, precisely as the Court is doing in this case.