on the amount of the claim from the date the claim was made by the insured in a p. 647 (E.D.Pa.1996) (explaining that the insured's references to sections of the UIPA that cover unfair claim or settlement practices if committed with such frequency as to indicate a business practice do not show that the insurer should be liable under § 8371 for wrongfully failing to defend or settle in a particular case). Toy v. Metro. Life Ins. Co., 928 A.2d 186, 200 n. 17 (Pa.2007); see also UPMC Health System v. Metro. Life Ins. Co., 391 F.3d 497, 505 (3d Cir.2004) (noting that the Supreme Court of Pennsylvania has not stated whether conduct that violates the UIPA constitutes bad faith for section 8371 claims). 11 . But see MacFarland v. United Stales Fid. & Guar. Co., 818 F.Supp. 108 (E.D.Pa.1993) (<HOLDING>); Rottmund v. Cont'l Assurance Co., 813 F.Supp.
holding that an insurer acted in bad faith by failing to keep the insured informed of settlement negotiations holding that the insured may make reference to a section in the uipa to illustrate its insurers bad faith behavior for refusing to pay a loss holding that the district court should consider the totality of the circumstances in determining whether the patentee acted in subjective bad faith and should consider whether circumstantial evidence would support an inference of bad faith holding that provisions of the uipa can be utilized to describe conduct constituting bad faith holding that the alleged conduct constituting violations of the uipa and the regulations can be considered in determining whether the insurer acted in bad faith under section 8371