under Insuring Agreement D’s “resulting directly from” requirement. It is not sensible under Insuring Agreement E’s less strict “by reason of’ requirement, where the word “directly” does not appear. See Merchs. Bank & Trust Co. v. Cincinnati Ins. Co., 2008 WL 728332, at *4 (S.D.Ohio March 14, 2008) (“Unlike Insuring Agreement D, there is no requirement [in Insuring Agreement E] that the loss be directly attributed to the forgery.” (emphasis added)). The Court, still mindful of Georgia law requiring construction of ambiguities against Cincinnati, holds Insuring Agreement E covers losses incurred when a bank extends credit on the basis of forged documents, notwithstanding the absence of underlying collateral. See ALEA London Ltd. v. Woodcock, 286 Ga.App. 572, 649 S.E.2d 740, 745 (2007) (<HOLDING>) (quoting Guar. Nat'l Ins. Co. v. Brock, 222
holding that only if provisions in an insurance contract are open to more than one interpretation should it be construed strictly against the insurer and liberally in favor of the insured holding ambiguities are strictly construed against the insurer as drafter holding pcra time limits are jurisdictional in nature and must be strictly construed holding that ambiguities in insurance contracts should be favorably construed to the insured holding that railroad immunity act should be strictly construed