(United States Third Circuit) – In an insurance action arising out of plaintiff Hanover Insurance’s alleged duty to defend or indemnify Urban Outfitters in a trademark infringement case brought by the Navajo nation, the district court’s grant of Hanover Insurance’s motion for judgment on the pleadings is affirmed where the underlying insurance fronting policy meets the publication exception to liability coverage. The court adopted a “common, clearly identifiable objectives” standard for applying the publication exception.