6th Circuit Denies $1 Million 'Loss of Referrals' Insurance Coverage Finding Temporary Closure Is Not Termination of Business
“Neither the complaint nor its exhibits explain which, if any, of the Key Referral Sources are permanently closed, how the relationship with any Key Referral Source has been permanently impacted by the suspended business, or how Retina Center determined it suffered a loss in excess of $1,000,000,” Judge John K. Bush wrote in the opinion. “Without that necessary information, the pleadings do not rise above speculation.”