Cream Liquidation, Inc., 281 B.R. 154, 160 (Bankr.D.Conn.2002). As a result, courts have disagreed as to what constitutes a “personal injury tort claim,” adopting one of three diverging views. Courts adopting the narrowest definition of the term hold that a personal injury tort claim requires an actual physical injury. See, e.g., Massey Energy Co. v. West Virginia Consumers for Justice, 351 B.R. 348, 351 (E.D.Va.2006); Cohen, 107 B.R. at 455. These courts conclude that Congress intended Section 157(b)(5) for a narrow range of claims, and that the focus should be on the “traditional, plain-meaning sense of those words.” Cohen, 107 B.R. at 455. Otherwise, jurisdiction would be too easily lost from bankruptcy courts, opening the d e (Primes), 388 B.R. 195, 199-200 (Bankr.N.D.W.Va.2008) (<HOLDING>); Bertholet, 126 B.R. at 416 (holding that a
holding that a claim for violation of the fair debt collection practices act is not a personal injury tort claim holding that a libel claim is a personal injury tort claim holding that a negligence claim is not a personal injury tort claim holding that an embezzlement claim is not a personal injury tort claim holding that a libel claim is not a personal injury tort claim