An occurrence “include[s] a single occurrence or a single accident, or a series of them arising out of one event or disaster.” This policy requires an occurrence during the policy, but it does not specify whether the resulting property damage or liability must take place during the policy period in order to trigger coverage. Dow contends that under Sixth Circuit case law, unless a policy specifies otherwise, both the causal event and the property damage can be the occurrence during the policy period on which coverage is based. See Michigan Chemical Corp. v. American Home Assurance Co., 728 F.2d 374, 381 (6th Cir.1984); see also Babcock & Wilcox Co. v. Arkwright-Boston Mfg. Mut. Ins. Co., 53 F.3d 762 (6th Cir.1995), cert denied, 516 U.S. 1140, 116 S.Ct. 973, 133 L.Ed.2d 893 (1996)(<HOLDING>). Dow reasons that because Michigan law is
holding that when a term is not defined in a contract the presumption is that the term is to be given its ordinary meaning and significance holding that the term occurrence was defined to mean any happening or series of happenings arising out of or due to one event taking place during the term of this contract holding that there can be no implied contractual term at variance with an express term of a contract holding that when a term is defined in the statute it need not be further alleged in the indictment holding that an additional term did not materially alter the contract because the plaintiff cannot profess to be surprised by an additional term in an invoice when the price quotation contained the identical term