Ironshore Indemnity Inc. v. Rogas

District Court, D. Nevada·Decided September 16, 2022·No. 2:21-cv-01706·Unknown

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 Ironshore Indemnity Inc., Case No.: 2:21-cv-01706-JAD-BNW

4 Plaintiff Order Granting Motion for Judgment on 5 v. the Pleadings in Favor of Plaintiff Ironshore Indemnity Inc. 6 Eric Kay, [ECF Nos. 54, 91] 7 Defendant

8 Ironshore Indemnity Inc. seeks a declaratory judgment that it has no duty to defend or 9 indemnify Eric Kay—the former Chief Legal Officer of the now-bankrupt cyber-security 10 company Cyber Litigation Inc.—for insurance claims arising from wrongful acts allegedly 11 committed by Cyber Litigation’s former Chief Executive Officer Adam Rogas. To obtain excess 12 insurance coverage from Ironshore, Rogas signed a warranty letter affirming that he and “all 13 insureds” had no knowledge or information of acts that could give rise to a claim under the 14 policy and dictating that any claims arising from such knowledge would be excluded from 15 coverage. Later, the U.S. Securities and Exchange Commission and the Department of Justice 16 filed civil and criminal suits against Rogas, alleging that he committed securities fraud while he 17 was CEO. 18 In 2021, Cyber Litigation sent a demand letter to Kay, claiming that he breached his 19 fiduciary duties to the company because he was on notice of Rogas’s fraud and did not report it 20 to the company’s board. Kay tendered that claim to Ironshore for coverage under the excess 21 policy, prompting this coverage suit. The parties cross-move for judgment on the pleadings, 22 with Ironshore seeking a declaratory judgment that Kay’s insurance claim is excluded from 23 coverage because it arises from Rogas’s prior knowledge of his own fraudulent conduct and Kay 1 arguing that Cyber Litigation’s demand letter against him does not fall within the exclusion. 2 Because Ironshore has shown that the warranty letter’s exclusion applies, I grant its motion and 3 deny Kay’s. 4 Background1 5 This insurance dispute arises from the downfall of NS8, a cyber-security company that

6 was based in Las Vegas, and the alleged wrongdoing of its co-founder and former CEO, Adam 7 Rogas. In March 2019, NS8 and Rogas obtained a $2 million directors-and-officers (D&O) 8 insurance policy from Scottsdale Insurance Company.2 Two months later, NS8 and Rogas 9 obtained an excess policy from Ironshore for $5 million.3 To obtain that excess coverage, Rogas 10 signed a warranty letter on behalf of himself and “all insureds” representing that “no insured has 11 knowledge or information of any act, error[,] or omission [that] might give rise to a claim(s), 12 suit(s)[,] or action(s) under either the first $2,000,000 limit of liability or Excess Limits . . . .”4 13 The warranty letter also stated that, “if such claim(s), suit(s), action(s), knowledge[,] or 14 information exists, then such claim(s), suit(s)[,] or action(s) and any claim(s), suit(s)[,] or

15 action(s) arising therefrom or arising from such knowledge or information is excluded from 16 coverage under the Excess Limits.”5 17 In November 2019, the U.S. Securities and Exchange Commission began investigating 18 NS8 and Rogas for securities fraud.6 The following year, the SEC and the U.S. Department of 19

1 These facts are taken from Ironshore’s complaint and exhibits attached to the complaint and 20 should not be construed as findings of fact. 21 2 ECF No. 3 at ¶ 2 (Ironshore’s complaint); see also ECF No. 3-2 (Scottsdale insurance policy). 3 ECF No. 3 at ¶ 2; see also ECF No. 3-3 (Ironshore excess policy). 22 4 ECF No. 3 at ¶ 2; see also ECF No. 3-4 (Ironshore warranty letter). 23 5 Id. 6 ECF No. 3 at ¶ 3. 1 Justice, respectively, filed a civil and a criminal suit against Rogas alleging that he “defrauded 2 investors by using forged documents to entice investors to purchase NS8 securities” and 3 “pocketed over $17.5 million that ha[d] been raised through his fraud.”7 Among the allegations 4 in the SEC lawsuit are that Rogas began defrauding investors as early as 2018—before he signed 5 the Ironshore warranty letter.8

6 In October 2020, NS8 filed for Chapter 11 bankruptcy protection in the U.S. Bankruptcy 7 Court for the District of Delaware.9 As part of that bankruptcy action, NS8 sold many of its 8 assets, including the rights to the name NS8, and changed its name to Cyber Litigation.10 In July 9 2021, attorneys for Cyber Litigation sent a demand letter to Eric Kay, co-founder and former 10 director and Chief Legal Officer of NS8, claiming that Kay breached his fiduciary duties to NS8 11 because he “gained intimate knowledge of material irregularities and alarming discrepancies 12 regarding NS8’s reported revenue and customer counts, financial controls, and corporate 13 governance practices” and failed to report those issues to NS8’s board.11 In the demand letter, 14 the Cyber Litigation attorneys allege that Kay “repeatedly learned of the aforementioned

15 irregularities and discrepancies through internal NS8 communications that put him on notice of 16 the fraud being perpetrated by NS8’s former CEO, Adam Rogas.”12 17 18 19

7 Id. 20 8 Id. at ¶ 4. 21 9 See In re Cyber Litigation Inc., Case No. 20-12702-CTG; see also ECF No. 3-8 at 4 (Kay demand letter). 22 10 ECF No. 5 at 4 n.1. 23 11 ECF No. 3-8 at 5. 12 Id. 1 Kay then notified Ironshore of the Cyber Litigation demand letter and requested coverage 2 under the excess policy.13 Ironshore disputes its coverage obligation and filed this action in 3 September 2021, seeking a declaratory judgment absolving it of the duties to defend or 4 indemnify Rogas, Kay, and “all [i]nsureds” for the government actions against Rogas and the 5 demand letter against Kay.14 In December, Ironshore voluntarily dismissed its claims against

6 Rogas and filed a motion for judgment on the pleadings as to its claims against Kay.15 Ironshore 7 contends that it has no duty to defend or indemnify Kay for the Cyber Litigation demand letter 8 because the allegations in it arose from wrongful acts that Rogas committed—and thus had 9 knowledge of—before he signed the Ironshore warranty letter.16 Kay also moves for judgment 10 on the pleadings, arguing that the warranty exclusion does not apply to his insurance claim 11 primarily because Ironshore has not proven that Rogas had “actual knowledge” of his 12 wrongdoing prior to signing the warranty letter and because non-imputation provisions in the 13 underlying policy prevent Ironshore from imputing any such knowledge to Kay.17 14 In March 2022, after most of the briefing on these competing motions was completed, 15 Rogas pled guilty to one count of securities fraud in the DOJ case against him.18 I permitted the

17 13 Id. at 2. 18 14 ECF No. 3 at 11–13. 15 ECF No. 53 (notice of voluntary dismissal); ECF No. 54 (motion for judgment on the 19 pleadings). 20 16 ECF No. 54. 17 ECF No. 91. 21 18 See U.S. v. Rogas, Case No. 20-cr-00539-JPC; ECF No. 96-3 (DOJ case docket); ECF No. 100-2 (DOJ press release). Also in March 2022, the court overseeing Cyber Litigation’s 22 bankruptcy action issued a confirmation order approving the appointment of a plan trustee and assigned all causes of action to the trustee, including the claims against Kay in the demand letter. 23 See ECF No. 96 at 2. But because this development doesn’t factor into my decision, I don’t address it here. 1 parties to file supplemental briefs to address the impact of that guilty plea on their argument.19 2 In its supplement, Ironshore argues that Rogas’s guilty plea “undoubtedly” triggers the warranty 3 exclusion.20 Kay responds that the guilty plea doesn’t clearly demonstrate that Rogas admitted 4 to having knowledge of wrongful acts prior to signing the Ironshore warranty letter in May 2019 5 and thus doesn’t impact whether the warranty exclusion applies.21

6 Discussion 7 I. Legal standards 8 A. Judgment on the pleadings 9

Ironshore Indemnity Inc. v. Rogas, (D. Nev. 2022).

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