See Eighth Floor Promotions, L.L.C. v. Cincinnati Ins. Co., 71 N.E.3d 1262, 1271-72 (Ohio Ct. App. 2016) (finding "audit request" that requested the insured "not attempt to enter into negotiations with any" software providers who may have sold the insured infringing software a demand for non-monetary relief); Weaver v. Axis Surplus Ins. Co., 2014 WL 5500667, at *8-11 (E.D.N.Y. Oct. 30, 2014) (defining demand for non-monetary relief in the terms discussed above and concluding letter from government entity that requested, among other things, "an injunction" requiring insured to "cease all offers and sales of [a] business opportunity" constituted a demand for non-monetary relief); Anderson-Tulley Co. v. Fed. Ins. Co., 2007 WL 9643297, at *1, *5 (W.D. Tenn. Aug. 7, 2007) (holding a letter that requested company refrain from issuing dividends beyond a "minimum level" in context of an impending fiduciary duty lawsuit constituted a demand for non-monetary relief). Cf. Zurich Am. Ins. Co. v. Syngenta Crop Prot., LLC, 2020 WL 5237318, at *8 (Del. Super. Ct. Aug. 3, 2020) (finding a letter that contained "an unclear or amorphous threat of future litigation" not "sufficient to constitute a claim" under the policy). Second, and more importantly, the Insurers' reading would widen the scope of the Claim definition unreasonably, resulting in impractical consequences for the insurance industry.

See Pfizer, 2019 WL 3306043, at *9 ("Proper construction of insurance policies depends largely on the type of policy provision at issue."). See Zurich Am. Ins. Co. v. Syngenta Crop Prot., LLC, 2020 WL 5237318, at *5 (Del. Super. Ct. Aug. 3, 2020) (citing E.I. du Pont de Nemours & Co. v. Allstate Ins. Co., 693 A.2d 1059, 1061 (Del. 1997)). See Pfizer, 2019 WL 3306043, at *9.