the Tenth Circuit summarized these principles aptly: The mere fact that Supervision was advertised or distributed at some point in time is not sufficient to transform Bur-son’s ownership infringement claims into advertising injury. See Novell [v. Federal Ins. Co.], 141 F.3d [983] at 988 [(10th Cir.1998)] (“The fact [the insured] may have advertised the competing product to consumers simply did not cause [the underlying plaintiffs] injuries”); see also Microtec Research, Inc. v. Nationwide Mut. Ins. Co., 40 F.3d 968, 971 (9th Cir.1994) (“If the [insured] does some wrongful act and then advertises it, harm caused by the wrongful act alone is not within the scope of the term advertising injury.”); Farmington [v. Cyberlogic Technologies, Inc.], 996 F.Supp. [695] at 702 [ (E.D.Mich.1998) ] (<HOLDING>). “Otherwise, advertising injury coverage would
holding that there must be some causal connection between the accident and the automobile allegedly involved for coverage to exist holding that there must be a causal connection between an insureds advertising and an alleged injury to trigger coverage for an advertising injury holding that causal connection between alleged injuries and advertising activity cannot be satisfied by a mere showing that the allegedly infringing product was advertised holding that five weeks between protected activity and adverse employment action insufficient to establish a causal connection holding that there must be a causal connection between the advertising activity and the injury alleged in the underlying complaint