In Westport Insurance Corp. v. M.L. Sullivan Insurance Agency, Inc., No. 15 C 7294, 2017 U.S. Dist. LEXIS 1527 (N.D. Ill. Jan. 5, 2017), an Illinois federal district court underscored the importance of a policyaEUR(TM)s damages requirement when it granted judgment on the pleadings in favor of Westport Insurance Corporation and against its insured M.L. Sullivan Insurance Agency. In the underlying suit, American Inter-Fidelity Exchange (AIFE) alleged Sullivan and one of its employees provided false information about insurance premiums due and requested damages representing the difference in premium amounts AIFE lost. As background, Sullivan had served as a broker and acquired from AIFE insurance for trucking and interstate transportation companies. Notably, Sullivan reported information about the power units and miles driven, and AIFE set premium amounts based on the information it had received from Sullivan. Sullivan, however, allegedly misrepresented the insuredsaEUR(TM) information, leading AIFE to believe it was owed a lower premium amount, whilst Sullivan kept the difference between what the insured paid Sullivan and what Sullivan tendered to AIFE. Sullivan sought a defense from Westport and, in response, Westport brought a declaratory action seeking a determination that it was not required to defend or indemnify Sullivan. SullivanaEUR(TM)s Professional Liability Insurance Policy issued by Westport provided coverage for claims that aEURoeseek damages arising from a wrongful act.aEUR? The policy then defined aEURoedamagesaEUR? as excluding aEURoereimbursement or return of premiums or fundsaEUR? for professional services rendered by Sullivan. In granting WestportaEUR(TM)s motion for judgment on the pleadings, the district court concluded that AIFEaEUR(TM)s complaint failed to satisfy the policyaEUR(TM)s definition of damages. While the complaint alleged SullivanaEUR(TM)s misreporting of information was a negligent act, and thus a aEURoewrongful act,aEUR? the recovery sought in the complaint was not within the policyaEUR(TM)s definition of damages because it explicitly excluded aEURoereimbursement or return of premiums.aEUR? Sullivan tried to assert that AIFEaEUR(TM)s request for compensatory damages involved more than just the withheld premium payments and also included damages for aEURoelost profits, lost business, damage to good will and reputation.aEUR? Nonetheless, the district court saw through the argument and reasoned that AIFE brought the suit in order to recover the wrongfully withheld premiums. The district court was also nonplussed by SullivanaEUR(TM)s argument that AIFEaEUR(TM)s inclusion of the phrase aEURoeall such further and other reliefaEUR? was something other than mere boilerplate language. As such, AIFEaEUR(TM)s complaint failed to seek damages within the purview of the policy. This case reminds insurers and insureds alike that not only must a complaint contain allegations of wrongdoing that would potentially fall within the policyaEUR(TM)s coverage, the complaint must also seek a type of relief covered by the policy.