17 . She posed one hypothetical example involving a small law firm that used the services of a courier to deliver papers or a snow plower in maintaining its building. 18 . 216 P.3d 1154 (Alaska 2009). 19 . Id. at 1176, 1178. 20 . Id. at 1178. 21 . Id. at 1177 (citing Warr v. Williamson, 359 Ark. 234, 195 S.W.3d 903, 904 (2004); Century 21 Today Inc. v. Tarrant, No. 240696, 2003 WL 22443624, at "1 (Mich.App. Oct.28, 2003)). 22 . Id. at 1178. 23 . While the dissent attempts to distinguish Beal because of the timing of the offer, Alyeska's offer, like that in Beal, "was effectively zero in what appears to be a good faith dispute involving potentially substantial damages." Beal, 216 P.3d at 1178. 24 . Id. 25 . Id. 26 . See Deltona House Rentals, Inc. v. Cloer, 734 So.2d 586, 588 (Fla. (<HOLDING>). 27 . Cf. Hartline v. Kaiser Found. Hosps.,
holding insurer not liable for bad faith when it denied insureds claim based on a good faith dispute regarding the interpretation of a rule holding that 101 offer of judgment was valid in a case of zero liability from the outset but noting that a low offer may not be in good faith when a legal dispute is novel or complex holding that lack of good faith is a valid basis to dismiss a chapter 7 case for cause under section 707a holding that the defendant did not establish good faith as a matter of law holding that bad faith includes lack of good faith in investigating the facts of a complaint