Business interruption insurance coverage is typically provided as part of a company's commercial property insurance. It is intended to protect businesses against income losses and extra expenses sustained as a result of certain disruptions in their operations arising from a covered cause of loss. As a result of COVID-19 pandemic shutdowns, there has been a flood of litigation brought by policy holders against insurance carriers arising from insureds' business interruptions. While several state legislators have proposed legislation aimed at addressing business interruption issues, insureds have sought more immediate relief from coverage denials by asserting claims of coverage for COVID-19 related business interruption.