In what appears to be the first decision of its kind in Pennsylvania, a federal district court in Philadelphia dismissed at the pleadings stage the plaintiff-insureds’ claims for insurance coverage based on COVID-19-related business interruption losses. In Wilson v. Hartford Cas. Co., No. 20-3384, 2020 U.S. Dist. LEXIS 179896 (E.D. Pa. Sept. 30, 2020), a Philadelphia attorney and her law firm filed a lawsuit against their insurer and broker seeking coverage for past and future business losses due to the Coronavirus and a myriad of associated state, city and court orders requiring the firm to close. The insureds claimed that coverage was available under their policy pursuant to the “civil authority”, “lost business income and extra expense”, “extended busines income”, “business income extension for essential personnel”, and “limited fungi, bacteria, or virus” provisions, the latter of which had a limit of $50,000. The insurer and broker both filed motions to dismiss the insureds’ amended complaint. Many of the early COVID-related business income rulings around the country have hinged upon whether coverage was triggered through “direct physical loss” or damage to the property at issue. The court in this case, however, stated that it need not decide this threshold issue because the policy’s “virus exclusion” – which precludes coverage for “loss or damage caused directly or indirectly by … [p]resence, growth, proliferation, spread or any activity of ‘fungi’, wet rot, dry rot, bacteria or virus” -- clearly and unambiguously applied, as the plaintiffs “explicitly allege that their losses are caused by the...