The Pennsylvania Supreme Court recently rendered its eagerly awaited decision in Ungarean v. CNA, declaring that losses resulting from COVID-related governmental closure orders were not covered by business interruption insurance. In the wake of that decision, the question remains as to whether the war over insurance coverage for COVID-related losses has been lost by policyholders in Pennsylvania or if Ungarean represents only a single battle in a longer, still-undecided war. A careful reading of Ungurean reveals the limited scope of its ruling.