Attorneys obtained summary judgment , on a coverage case brought by a school district against an insurance company. The District was a victim of "phishing" by a russian criminal ring and sought coverage for its losses under its commercial property policy. The attorneys' convinced the Court that the policy forgery coverage was not applicable because the electronic instruction did not constitute a "writing" as defined under the Uniform Commercial Code. The Court did find an ambiguity under a separate coverage form for "theft"; however, that coverage was subject to a small sublimit.