A court of the Northern District of Texas granted a motion for continuance upon which the Court requested briefing as to whether a live case and controversy exists, rejecting the insurer's argument that the independent injury rule applies and finding that the case did present a live case and controversy where, even though an insured's claim for damaged artwork exceeded policy limits, the insured had properly pleaded reliance upon an insurer's alleged misrepresentation regarding the limit of coverage for valuable artwork under a commercial property policy at the time of procurement, meeting the Article III injury-in-fact requirement.
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