The United States District Court for the Eastern District of Pennsylvania, applying Pennsylvania law, has held that a letter notifying the insured of the sender’s intent to file a joinder complaint, i.e., a third-party claim, against it constituted a Claim under the insured’s claims-made professional liability insurance policy. Landmark Am. Ins. Co. v. NurSelect LLC, 2025 WL 673632 (E.D. Pa. Mar. 3, 2025). The court further held that the letter, which was sent via email, was received on the date it was sent, (prior to the Policy Period), rather than when it was read (during the Policy Period).