In Owners Ins. Co. v. European Auto Works, Inc., Civ. No. 10-2868 (RHK/JJG) (D. Minn.), the U.S. District Court for the District of Minnesota concluded that CGL and umbrella policies that provided coverage for "advertising injury" arising from the "oral or written publication of material that violates a person’s right of privacy" provided coverage for a Telephone Consumer Protection Act (TCPA) claim.