The United States Second Circuit Court of Appeals recently held that the selling of goods with a counterfeit brand label did not constitute covered advertising injury. In U.S. Fidelity & Guar. Co. v. Fendi Adele S.R.I., 823 F.3d 146 (2d Cir. 2016), the insured, Ashley Reed Trading, Inc. was in the business of purchasing and selling off-price branded handbags and other luxury goods. Ashley Reed was insured by USF&G which provided coverage for defined "advertising injury." The policy defined "advertising injury" as "attracting the attention of others by any means for the purpose of seeking customers or supporters or increasing sales or business." The policy set forth four advertising injury offenses, including the "use of another's advertising idea" or other "advertising" and the "infringement of another's copyright, trade dress or slogan in your 'advertising.'"