A court of the Northern District of Texas resolved cross-motions for summary judgment in a commercial crime policy dispute over the recovery of funds stolen through a phishing scam, holding that the policy's allocation of recovery provision is limited to only those recoveries of loss that resulted from a covered occurrence and that a fact issue remains as to whether any portion of funds remitted to the insured through the United States Secret Service's recovery efforts consists of funds stolen as a result of a covered occurrence.
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