Massachusetts General Laws

Mass. Gen. Laws ch. 176D, § 3 (2026)

Unfair methods of competition and unfair or deceptive acts or practices

✓ current as of July 2026
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Section 3. The following are hereby defined as unfair methods of competition and unfair or deceptive acts or practices in the business of insurance:—

(1) Misrepresentations and false advertising of insurance policies: making, issuing, circulating, or causing to be made, issued or circulated, any estimate, illustration, circular or statement which:—

(a) Misrepresents the benefits, advantages, conditions, or terms of any insurance policy;

(b) Misrepresents the dividends or shares of the surplus to be received on any insurance policy;

(c) Makes any false or misleading statements as to the dividends or share or surplus previously paid on any insurance policy;

(d) Misleads or misrepresents the financial condition of any person or the legal reserve system upon which any life insurer operates;

(e) Uses any name or title of any insurance policy or class of insurance policies misrepresenting the true nature thereof;

(f) Misrepresents for the purpose of inducing or tending to induce the lapse, forfeiture, exchange, conversion, or surrender of any insurance policy;

(g) Misrepresents for the purpose of effecting a pledge or assignment of or effecting a loan against any insurance policy; or

(h) Misrepresents any insurance policy as being shares of stock.

(2) False information and advertising generally: making, publishing, disseminating, circulating, or placing before the public, or causing, directly or indirectly, to be made, published, disseminated, circulated, or placed before the public, in newspaper, magazine or other publication, or in the form of a notice, circular, pamphlet, letter or poster or over any radio or television station, or in any other way, an advertisement, announcement or statement containing any assertion, representation or statement with respect to the business of insurance or with respect to any person in the conduct of his insurance business, which is untrue, deceptive or misleading.

(3) Defamation: making, publishing, disseminating, or circulating, directly or indirectly, or aiding, abetting or encouraging the making, publishing, disseminating or circulating of any oral or written statement or any pamphlet, circular, article or literature which is false, or maliciously critical of or derogatory to the financial condition of any person, and which is calculated to injure such person.

(4) Boycott, coercion and intimidation: (a) entering into an agreement to commit, or by concerted action committing, an act of boycott, coercion or intimidation resulting in or tending to result in unreasonable restraint of, or monopoly in, the business of insurance; (b) an refusal by a nonprofit hospital service corporation, medical service corporation, insurance or health maintenance organization to negotiate, contract or affiliate with a health care facility or provider because of such facility's or provider's contracts, type of provider licensure or affiliations with any other nonprofit hospital service corporation, medical service corporation, insurance company or health maintenance organization; or (c) an nonprofit hospital service corporation, medical service corporation, insurance company or health maintenance organization establishing the price to be paid to any health care facility or provider by reference to the price paid, or the average of prices paid, to such facility or provider under a contract or contracts with any other nonprofit hospital service corporation, medical service corporation, insurance company, health maintenance organization or preferred provider arrangement.

(5) False statements and entries: (a) knowingly filing with any supervisory or other public official, or knowingly making, publishing, disseminating, circulating or delivering to any person, or placing before the public, or knowingly causing directly or indirectly, to be made, published, disseminated, circulated, delivered to any person, or placed before the public, any false material statement of fact as to the financial condition of a person; or (b) knowingly making any false entry of a material fact in any book, report or statement of any person or knowingly omitting to make a true entry of any material fact pertaining to the business of such person in any book, report or statement of such person.

(6) Stock operations and advisory board contracts: issuing or delivering or permitting agents, officers or employees to issue or deliver, agency company stock or other capital stock, or benefit certificates or shares in any common-law corporation, securities or any special or advisory board contracts or other contracts of any kind promising returns and profits as an inducement to insurance.

(7) Unfair discrimination: (a) making or permitting any unfair discrimination between individuals of the same class and equal expectation of life in the rates charged for any contract of life insurance or of life annuity or in the dividends or other benefits payable thereon, or in any other of the terms and conditions of such contract; or (b) making or permitting any unfair discrimination between individuals of the same class and of essentially the same hazard in the amount of premium, policy fees, or rates charged for any policy or contract of accident or health insurance or in the benefits payable thereunder, or in any of the terms or conditions of such contract, or in any other manner whatever.

(8) Rebates: Except as otherwise expressly provided by law, knowingly permitting or offering to make or making any insurance contract, including but not limited to a contract for life insurance, life annuity or accident and health insurance, or agreement as to such contract other than as plainly expressed in the insurance contract issued thereon, or paying or allowing, or giving or offering to pay, allow, or give, directly or indirectly, as inducement to such insurance or annuity any rebate of premiums payable on the contract, or any special favor or advantage in the dividends or other benefits thereon, or any valuable consideration or inducement whatever not specified in the contract; or giving, or selling, or purchasing or offering to give, sell, or purchase as inducement to such insurance contract, or annuity or in connection therewith, any stocks, bonds, or other securities of any insurance company or other corporation, association, or partnership, or any dividends or profits accrued thereon, or anything of value whatsoever not specified in the contract.

Nothing in clauses (7) or (8) of this subsection shall be construed as including within the definition of discrimination or rebates any of the following practices:—(i) in the case of any contract of life insurance or life annuity, paying bonuses to policyholders or otherwise abating their premiums in whole or in part out of surplus accumulated from nonparticipating insurance, provided that any such bonuses or abatement of premiums shall be fair and equitable to policyholders and for the best interests of the company and its policyholders; (ii) in the case of life insurance policies issued on the industrial debit plan, making allowance to policyholders who have continuously for a specified period made premium payment directly to an office of the insurer in the amount which fairly represents the saving in collection expenses; (iii) readjustment of the rate of premium for a group insurance policy based on the loss or expense experienced thereunder, at the end of the first or any subsequent policy year of insurance thereunder, which may be made retroactive only for such policy year.

(9) Unfair claim settlement practices: An unfair claim settlement practice shall consist of any of the following acts or omissions:

(a) Misrepresenting pertinent facts or insurance policy provisions relating to coverages at issue;

(b) Failing to acknowledge and act reasonably promptly upon communications with respect to claims arising under insurance policies;

(c) Failing to adopt and implement reasonable standards for the prompt investigation of claims arising under insurance policies;

(d) Refusing to pay claims without conducting a reasonable investigation based upon all available information;

(e) Failing to affirm or deny coverage of claims within a reasonable time after proof of loss statements have been completed;

(f) Failing to effectuate prompt, fair and equitable settlements of claims in which liability has become reasonably clear;

(g) Compelling insureds to institute litigation to recover amounts due under an insurance policy by offering substantially less than the amounts ultimately recovered in actions brought by such insureds;

(h) Attempting to settle a claim for less than the amount to which a reasonable man would have believed he was entitled by reference to written or printed advertising material accompanying or made part of an application;

(i) Attempting to settle claims on the basis of an application which was altered without notice to, or knowledge or consent of the insured;

(j) Making claims payments to insured or beneficiaries not accompanied by a statement setting forth the coverage under which payments are being made;

(k) Making known to insured or claimants a policy of appealing from arbitration awards in favor of insureds or claimants for the purpose of compelling them to accept settlements of compromises less than the amount awarded in arbitration;

(l) Delaying the investigation or payment of claims by requiring that an insured or claimant, or the physician of either, submit a preliminary claim report and then requiring the subsequent submission of formal proof of loss forms, both of which submissions contain substantially the same information;

(m) Failing to settle claims promptly, where liability has become reasonably clear, under one portion of the insurance policy coverage in order to influence settlements under other portions of the insurance policy coverage; or

(n) Failing to provide promptly a reasonable explanation of the basis in the insurance policy in relation to the facts or applicable law for denial of a claim or for the offer of a compromise settlement.

(10) Failure to maintain complaint handling procedures; failure of any person to maintain a complete record of all of the complaints which it has received since the date of its last examination, which record shall indicate in such form and detail as the commissioner may from time to time prescribe, the total number of complaints, their classification by line of insurance, and the nature, disposition, and time of processing of each complaint. For purposes of this subsection, ''complaint'' shall mean any written communication primarily expressing a grievance. Agents, brokers and adjusters shall maintain any written communications received by them which express a grievance for a period of two years from receipt, with a record of their disposition, which shall be available for examination by the commissioner at any time.

(11) Misrepresentation in insurance applications: making false or fraudulent statements or representations on or relative to an application for an insurance policy, for the purpose of obtaining a fee, commission, money, or other benefit from any insurers, agent, broker, or individual.

(12) A violation of section 2B, 95, 113X, 181 to 183, inclusive, 187B to 187D, inclusive, 189, 193E or 193K of chapter 175.

Notes of Decisions
Cited in 437 cases (41 in the last 5 years), 1972–2026 · leading case: Hopkins v. Liberty Mut. Ins., 750 N.E.2d 943 (Mass. 2001).
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Hopkins v. Liberty Mut. Ins., 750 N.E.2d 943 (Mass. 2001). · cites it 34× “After a jury-waived trial, a judge in the Superior *557 Court concluded that the defendant, Liberty Mutual Insurance Company, had committed knowing and wilful violations of G. L. c. 176D, § 3 (9) (f), and G. L. c. 93A, §§ 2 and 9, by acting unfairly and deceptively in settling a…”
R.W. Granger & Sons, Inc. v. J & S Insulation, Inc., 435 Mass. 66 (Mass. 2001). · cites it 20× “8 He found that USF&G had failed to conduct “a reasonable investigation” of Granger’s dispute with J&S both prior to and after the jury verdict, in violation of G. L. c. 176D, § 3 (9) (d) (see note 3, supra); failed to exercise its duty to “affirm or deny coverage of claims…”
Wheatley v. Massachusetts Insurers Insolvency Fund, 925 N.E.2d 9 (Mass. 2010). · cites it 20× “” 2 G. L. c. 176D, § 3. General Laws c. 93A, § 9 (1), in turn, provides, among other *595 things, that a consumer “whose rights are affected by another person violating the provisions of” G.”
Clegg v. Butler, 424 Mass. 413 (Mass. 1997). · cites it 14× “These cross appeals in this case arise from a claim brought by the plaintiffs against the defendant insurer, Utica Mutual Insurance Company (Utica), alleging unfair settlement practices in violation of G. L. c. 176D, § 3 (9) (f), and seeking damages under G.”
Van Dyke v. St. Paul Fire & Marine Ins. Co., 448 N.E.2d 704 (Mass. 1983). · cites it 12× “93A and G.L.c. 176D, § 3 (9)]." On June 15, 1981, St.”
Gore v. Arbella Mut. Ins., 932 N.E.2d 837 (Mass. App. Ct. 2010). · cites it 16× “556, 562 (2001) (purpose of G. L. c. 176D, § 3, is to “remedy a host of possible violations in the insurance industry and to subject insurers committing violations to the remedies available to an injured party under G.”
Schwartz v. Travelers Indem. Co., 740 N.E.2d 1039 (Mass. App. Ct. 2001). · cites it 6× “175, § 99, and contained in a homeowner’s insurance policy, governs a claim for unfair claim settlement practices described in G. L. c. 176D, § 3(9), and brought pursuant to G.”
Rhodes v. AIG Dom. Claims, Inc., 937 N.E.2d 471 (Mass. App. Ct. 2010). · cites it 28× “The Legislature has placed the duty on the insurer to effectuate settlements by proceeding promptly with a reasonable settlement offer, thereby reducing the uncertainties and frustrations that inevitably follow from needless delay and the complications of litigation.”
Transamerica Ins. Grp. v. Turner Constr. Co., 601 N.E.2d 473 (Mass. App. Ct. 1992). · cites it 9× “93A, § 11, and G. L. c. 176D, § 3(9). The factual basis for its claim under either statute is that Transamerica belatedly tried to saddle Liberty with Turner’s defense and, after failing in that effort, settled the Davis case and sought to stick Liberty with the bill.”
Davis v. Allstate Ins., 747 N.E.2d 141 (Mass. 2001). · cites it 6× “The Lazaris decision, however, dealt solely with a pretrial settlement offer, specifically, whether an insurance company violates G. L. c. 176D, § 3 (9) (f), and G. L. c. 93A by insisting that a claimant release all claims against its insured before it pays a claim.”
River Farm Realty Trust v. Farm Fam. Cas. Ins. Co., 943 F.3d 27 (1st Cir. 2019). · cites it 4× “The pertinent state law, chapter 176D, section 3 states that "unfair claim settlement practices" constitute "unfair methods of competition and unfair or deceptive acts or practices in the business of insurance.”
Boston Symphony Orchestra, Inc. v. Com. Union Ins., 545 N.E.2d 1156 (Mass. 1989). · cites it 4× “93A, and G. L. c. 176D, § 3 (9) (1988 ed.). A judge of the Superior Court allowed the BSO’s motion for summary judgment on Count I, and allowed Commercial Union’s motion for summary judgment on Count II.”
Show all 437 citing cases →
— Mass. Gen. Laws ch. 176D, § 3(1) — 4 cases
Ryan v. Fallon Cmty. Health Plan, Inc., 921 F. Supp. 34 (D. Mass. 1996).
Grande v. PFL Life Ins., 2000 Mass. App. Div. 261 (Mass. Dist. Ct., App. Div. 2000).
Pitcherville Sand & Gravel, Inc. v. Holden Sand & Gravel Co., 24 Mass. L. Rptr. 243 (Mass. Super. Ct. 2008).
Falvey v. United States Fire Ins. Co. (D. Mass. 2025).
— Mass. Gen. Laws ch. 176D, § 3(1)(a) — 2 cases
McKinnon v. Unum Grp. (D. Mass. 2021).
Gottlieb v. Amica Mut. Ins. Co. (D. Mass. 2022).
— Mass. Gen. Laws ch. 176D, § 3(1)(f) — 1 case
Day v. Kerkorian, 814 N.E.2d 745 (Mass. App. Ct. 2004).
— Mass. Gen. Laws ch. 176D, § 3(11) — 1 case
Debral Realty, Inc. v. Ticor Title Ins., 9 Mass. L. Rptr. 156 (Mass. Super. Ct. 1998).
— Mass. Gen. Laws ch. 176D, § 3(2) — 1 case
Mitzan v. Medview Servs., Inc., 10 Mass. L. Rptr. 242 (Mass. Super. Ct. 1999).
— Mass. Gen. Laws ch. 176D, § 3(4) — 2 cases
Shah v. Liberty Mut. Ins., 776 N.E.2d 1020 (Mass. App. Ct. 2002).
Shah v. Liberty Mut. Ins., 2000 Mass. App. Div. 210 (Mass. Dist. Ct., App. Div. 2000).
— Mass. Gen. Laws ch. 176D, § 3(5) — 1 case
David v. Comm'r of Ins., 757 N.E.2d 748 (Mass. App. Ct. 2001).
— Mass. Gen. Laws ch. 176D, § 3(8) — 2 cases
Van Emden Mgmt. Corp. v. Marsh & McLennan Companies, 20 Mass. L. Rptr. 79 (Mass. Super. Ct. 2005).
Mitzan v. Medview Servs., Inc., 10 Mass. L. Rptr. 242 (Mass. Super. Ct. 1999).
— Mass. Gen. Laws ch. 176D, § 3(9) — 212 cases
Gore v. Arbella Mut. Ins., 932 N.E.2d 837 (Mass. App. Ct. 2010). “556, 562 (2001) (purpose of G. L. c. 176D, § 3, is to “remedy a host of possible violations in the insurance industry and to subject insurers committing violations to the remedies available to an injured party under G.”
Schwartz v. Travelers Indem. Co., 740 N.E.2d 1039 (Mass. App. Ct. 2001). “175, § 99, and contained in a homeowner’s insurance policy, governs a claim for unfair claim settlement practices described in G. L. c. 176D, § 3(9), and brought pursuant to G.”
Transamerica Ins. Grp. v. Turner Constr. Co., 601 N.E.2d 473 (Mass. App. Ct. 1992). “93A, § 11, and G. L. c. 176D, § 3(9). The factual basis for its claim under either statute is that Transamerica belatedly tried to saddle Liberty with Turner’s defense and, after failing in that effort, settled the Davis case and sought to stick Liberty with the bill.”
Rhodes v. AIG Dom. Claims, Inc., 937 N.E.2d 471 (Mass. App. Ct. 2010). “The Legislature has placed the duty on the insurer to effectuate settlements by proceeding promptly with a reasonable settlement offer, thereby reducing the uncertainties and frustrations that inevitably follow from needless delay and the complications of litigation.”
Silva v. Steadfast Ins. Co., 35 N.E.3d 401 (Mass. App. Ct. 2015).
— Mass. Gen. Laws ch. 176D, § 3(9)(1) — 1 case
United States Ex Rel. Metric Elec., Inc. v. EnviroServe, Inc., 301 F. Supp. 2d 56 (D. Mass. 2003).
— Mass. Gen. Laws ch. 176D, § 3(9)(a) — 16 cases
Gore v. Arbella Mut. Ins., 932 N.E.2d 837 (Mass. App. Ct. 2010). “556, 562 (2001) (purpose of G. L. c. 176D, § 3, is to “remedy a host of possible violations in the insurance industry and to subject insurers committing violations to the remedies available to an injured party under G.”
John Beaudette, Inc. v. Sentry Ins. a Mut. Co., 94 F. Supp. 2d 77 (D. Mass. 1999).
Ora Catering, Inc. v. Northland Ins., 57 F. Supp. 3d 102 (D. Mass. 2014).
Brazas Sporting Arms, Inc. v. Am. Empire Surplus Lines Ins., 220 F.3d 1 (1st Cir. 2000).
Aquino v. Pacesetter Adjustment Co., 416 F. Supp. 2d 181 (D. Mass. 2005).
— Mass. Gen. Laws ch. 176D, § 3(9)(b) — 13 cases
River Farm Realty Trust v. Farm Fam. Cas. Ins. Co., 943 F.3d 27 (1st Cir. 2019). “The pertinent state law, chapter 176D, section 3 states that "unfair claim settlement practices" constitute "unfair methods of competition and unfair or deceptive acts or practices in the business of insurance.”
United States Ex Rel. Metric Elec., Inc. v. EnviroServe, Inc., 301 F. Supp. 2d 56 (D. Mass. 2003).
Whitney v. Cont'l Ins., 595 F. Supp. 939 (D. Mass. 1984).
Hartford Fire Ins. Co. v. CNA INS. CO.(Eur.), 678 F. Supp. 2d 1 (D. Mass. 2010).
Bohn v. Vermont Mut. Ins., 922 F. Supp. 2d 138 (D. Mass. 2013).
— Mass. Gen. Laws ch. 176D, § 3(9)(c) — 9 cases
John Beaudette, Inc. v. Sentry Ins. a Mut. Co., 94 F. Supp. 2d 77 (D. Mass. 1999).
Vermont Mut. Ins. v. Maguire, 662 F.3d 51 (1st Cir. 2011).
Behn v. Legion Ins., 173 F. Supp. 2d 105 (D. Mass. 2001).
Martorana v. Progressive Direct Ins. Co. (D. Mass. 2023).
Caira v. Zurich Am. Ins. Co. (Mass. App. Ct. 2017).
— Mass. Gen. Laws ch. 176D, § 3(9)(d) — 28 cases
Olin Corp. v. OneBeacon Am. Ins. Co., 864 F.3d 130 (2d Cir. 2017).
River Farm Realty Trust v. Farm Fam. Cas. Ins. Co., 943 F.3d 27 (1st Cir. 2019). “The pertinent state law, chapter 176D, section 3 states that "unfair claim settlement practices" constitute "unfair methods of competition and unfair or deceptive acts or practices in the business of insurance.”
United States Ex Rel. Metric Elec., Inc. v. EnviroServe, Inc., 301 F. Supp. 2d 56 (D. Mass. 2003).
Ferrara & DiMercurio, Inc. v. St. Paul Mercury Ins., 169 F.3d 43 (1st Cir. 1999).
Cytosol Labs., Inc. v. Fed. Ins., 536 F. Supp. 2d 80 (D. Mass. 2008).
— Mass. Gen. Laws ch. 176D, § 3(9)(e) — 7 cases
Gore v. Arbella Mut. Ins., 932 N.E.2d 837 (Mass. App. Ct. 2010). “556, 562 (2001) (purpose of G. L. c. 176D, § 3, is to “remedy a host of possible violations in the insurance industry and to subject insurers committing violations to the remedies available to an injured party under G.”
United States Ex Rel. Metric Elec., Inc. v. EnviroServe, Inc., 301 F. Supp. 2d 56 (D. Mass. 2003).
Shapiro v. Am. Home Assurance Co., 616 F. Supp. 906 (D. Mass. 1985).
River Farm Realty Trust v. Farm Fam. Cas. Ins. Co. (D. Mass. 2019).
Merchants Preferred Ins. v. Konstantinopoulos, 32 Mass. L. Rptr. 310 (Mass. Super. Ct. 2014).
— Mass. Gen. Laws ch. 176D, § 3(9)(f) — 105 cases
Nat'l Union Fire Ins., Pitts., Pa. v. W. Lake Acad., 548 F.3d 8 (1st Cir. 2008).
Bingham v. Supervalu, Inc., 806 F.3d 5 (1st Cir. 2015).
M.J. Flaherty Co. v. United States Fid. & Guar. Co., 810 N.E.2d 823 (Mass. App. Ct. 2004).
Nat'l Union Fire Ins. v. West Lake Academy, 548 F.3d 8 (1st Cir. 2008).
Sanders v. Phoenix Ins. Co., 843 F.3d 37 (1st Cir. 2016).
— Mass. Gen. Laws ch. 176D, § 3(9)(f)(m) — 1 case
Peckham v. Cont'l Cas. Ins., 997 F. Supp. 73 (D. Mass. 1989).
— Mass. Gen. Laws ch. 176D, § 3(9)(g) — 15 cases
Guity v. Com. Ins. Co., 631 N.E.2d 75 (Mass. App. Ct. 1994).
Bohn v. Vermont Mut. Ins., 922 F. Supp. 2d 138 (D. Mass. 2013).
Forcucci v. United States Fid. & Guar. Co., 817 F. Supp. 195 (D. Mass. 1993).
Watts Water Tech., Inc. v. Fireman's Fund Ins., 22 Mass. L. Rptr. 659 (Mass. Super. Ct. 2007).
Michael v. Trustmark Ins., 16 Mass. L. Rptr. 245 (Mass. Super. Ct. 2003).
— Mass. Gen. Laws ch. 176D, § 3(9)(h) — 1 case
N. Sec. Ins. v. R.H. Realty Trust, 25 Mass. L. Rptr. 185 (Mass. Super. Ct. 2009).
— Mass. Gen. Laws ch. 176D, § 3(9)(i) — 1 case
P. Gioioso & Sons, Inc. v. Liberty Mut. Ins., 33 Mass. L. Rptr. 511 (Mass. Super. Ct. 2016).
— Mass. Gen. Laws ch. 176D, § 3(9)(m) — 1 case
Bohn v. Vermont Mut. Ins., 922 F. Supp. 2d 138 (D. Mass. 2013).
— Mass. Gen. Laws ch. 176D, § 3(9)(n) — 7 cases
Bohn v. Vermont Mut. Ins., 922 F. Supp. 2d 138 (D. Mass. 2013).
Rli Ins. Co. v. Santos, 746 F. Supp. 2d 255 (D. Mass. 2010).
O'Hara v. The Stand. Fire Ins. Co. (D. Mass. 2018).
Mont v. Encompass Ins., 32 Mass. L. Rptr. 39 (Mass. Super. Ct. 2014).
Caira v. Zurich Am. Ins. Co. (Mass. App. Ct. 2017).
— Mass. Gen. Laws ch. 176D, § 3(a) — 3 cases
Dattilo v. Arbella Mut. Ins., 22 Mass. L. Rptr. 447 (Mass. Super. Ct. 2007).
Tallent v. Liberty Mut. Ins., 19 Mass. L. Rptr. 460 (Mass. Super. Ct. 2005).
Bianchi v. Arbella Mut. Ins., 8 Mass. L. Rptr. 114 (Mass. Super. Ct. 1997).
— Mass. Gen. Laws ch. 176D, § 3(d) — 1 case
Boyle v. Zurich Am. Ins., 31 Mass. L. Rptr. 139 (Mass. Super. Ct. 2013).
— Mass. Gen. Laws ch. 176D, § 3(e) — 1 case
Dattilo v. Arbella Mut. Ins., 22 Mass. L. Rptr. 447 (Mass. Super. Ct. 2007).
— Mass. Gen. Laws ch. 176D, § 3(g) — 1 case
Taveras v. Rodriquez, 2000 Mass. App. Div. 39 (Mass. Dist. Ct., App. Div. 2000).
— Mass. Gen. Laws ch. 176D, § 3(l)(a) — 2 cases
Foisy v. Royal MacCabees Life Ins., 241 F. Supp. 2d 65 (D. Mass. 2002).
Debral Realty, Inc. v. Ticor Title Ins., 9 Mass. L. Rptr. 156 (Mass. Super. Ct. 1998).
— Mass. Gen. Laws ch. 176D, § 3(l)(g) — 1 case
Sokhos v. Mayflower Transit, Inc., 691 F. Supp. 1578 (D. Mass. 1988).
— Mass. Gen. Laws ch. 176D, § 3(m) — 1 case
Dattilo v. Arbella Mut. Ins., 22 Mass. L. Rptr. 447 (Mass. Super. Ct. 2007).
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