Mutual contends that the district court erred by equating the terms “claim” and “cause of action” in its analysis. According to Liberty Mutual, the negligence and breach of contract “causes of action” each contained potential and nonpotential “claims” that must be segregated for purposes of reimbursement. Neither Buss nor subsequent California cases, however, support Liberty Mutual’s argument. The potential or nonpotential “claims” in question are the very same “causes of action” denoted in the state court complaint. See id. at 784 (describing the relevant test as whether “specific costs can be allocated solely to the causes of action that were not even potentially covered”); see also Hameid v. Nat’l Fire Ins. of Hartford, 31 Cal.4th 16, 1 Cal.Rptr.3d 401, 71 P.3d 761, 770 (2003) (<HOLDING>). Liberty Mutual’s duty to defend continued
holding that there is a duty to defend if any of the complaints allegations fall within the risk covered by the policy holding that an insurer had no duty to defend in the absence of any cause of action amounting to a potentially covered offense under the  insurance policy holding that the insurer had no duty to defend the insured because the allegations of the initial complaint did not allege facts which would bring the case within the coverage of the title insurance policy recognizing in context of general liability policy if petition contains allegations which when fairly and reasonably construed state cause of action potentially covered by policy insurer has duty to defend insured in underlying suit holding that insurer had a continuing duty to defend