(United States Third Circuit) – In a contract action arising from plaintiff’s offer to renew defendant’s insurance contact on substantially different terms and raising the question of what constitutes a renewal under Pennsylvania contract law, the district court’s denial of defendant’s summary judgment motion is vacated and the court held that: 1) renewal requires continuation of coverage on the same, or nearly the same, terms as the policy being renewed; and 2) plaintiff’s offer of a revised insurance contract to defendant did not constitute an renewal where the price, term, coverage limit, and scope of the coverage differed.