The United States District Court for the District of Colorado, applying Colorado law, has held that claimants were not entitled to coverage for default judgments because the insured dentist failed to provide notice of the claims. Nat’l Union Fire Ins. Co. of Pittsburgh, PA v. Estate of Calendine, 2022 WL 17486796 (D. Colo. Dec. 7, 2022). Making an “Erie guess,” the court reasoned that the Colorado Supreme Court would be unlikely to hold that the insurers needed to demonstrate prejudice from late notice to deny coverage.