We obtained dismissal of our insurance broker client on Motion for Judgment on the Pleadings in the Philadelphia County Court of Common Pleas on the basis of a statute of limitations defense. Plaintiff alleged a failure to procure insurance that would cover an employee’s death in the course of business operations. We successfully argued that the four-year statute of limitations applicable to breach of contract claims barred plaintiff’s claims based upon several instances of notice of the insurance policy terms and coverages, and a claim determination, all of which preceded the suit inception by more than four years.