The U.S. District Court for the District of New Jersey, applying New Jersey law, has held that a misappropriation of funds exclusion unambiguously barred coverage for an accounting firm under its professional liability policy based on the allegations in the complaint, regardless of the insured’s defense that a third party, not the firm, committed the misappropriation. Certain Underwriters at Lloyd’s, London v. Drosos, 2024 WL 2292343 (D.N.J. May 21, 2024).