MEMORANDUM Unlike some commercial general liability policies, the Policy’s definition of advertising does not include information “directed at specific market segments.” Hameid v. Nat’l Fire Ins. of Hartford, 31 Cal.4th 16, 1 Cal.Rptr.3d 401, 71 P.3d 761, 766 n. 3 (2003). And, rather than broadcast a message out to the general public, Eurocon-cepts, Inc. (“Euroconcepts”) passively distributed the flyer at issue only to those potential customers who happened to walk into its showroom. The flyer thus cannot fall within the Policy’s definition of advertising, see id. at 766, 769-70; Rombe Corp. v. Allied Ins.
Co., 128 Cal.App.4th 482, 27 Cal.Rptr.3d 99, 107 (2005), so Hartford Casualty Insurance Company (“Hartford”) had no duty to defend the underlying action. See Montrose Chem. Corp. v. Superior Court, 6 Cal.4th 287, 24 Cal.Rptr.2d 467, 861 P.2d 1153, 1157 (1993); Gray v. Zurich Ins. Co., 65 Cal.2d 263, 54 Cal.Rptr. 104, 419 P.2d 168, 176 n. 15 (1966). We further reject Euroconcepts’ argument that Hartford had a duty to defend because some suppliers who installed products in the allegedly infringing residence used photographs of those products in magazines or other publications.
The Policy expressly covers only Euroconcepts’ own advertisements. The underlying action alleged only that Euroconcepts palmed off copyrighted designs. Hartford therefore had no duty to defend based on the Policy’s coverage of injury from the “publication of material that slanders or libels a person or organization or disparages a person’s or organization’s goods, products or services.” See Microtec Research, Inc. v. Nationwide Mut. Ins. Co., 40 F.3d 968, 972 (9th Cir.1994). AFFIRMED. This disposition is not appropriate for publication and is not precedent except as provided by 9th Cir. R. 36-3.