Peoples Church of Fresno, 985 F2d 446, 450 (I) (9th Cir. 1993) (discussing a claim by consumers for misrepresentation as a species of unfair competition, “[aldvertising injury ... is injury inflicted on a competitor and not simply on a customer”). 16 See Elan Pharmaceutical Research Corp. v. Employers Ins. of Wausau, 144 F3d 1372, 1375 (I) (11th Cir. 1998) (“[t]o fall within the coverage of the insurance policies,... there must have been some causal connection between the advertising injury and the advertising activity”); Hyman v. Nationwide Mut. Fire Ins. Co., 304 F3d 1179, 1191-1192 (I) (B) (11th Cir. 2002) (“ ‘the injury for which coverage is sought must be caused by the advertising itself ”); Robert Bowden, Inc. v. Aetna Cas. & Surety Co., 977 FSupp. 1475, 1480-1481 (N.D. Ga. 1997) (<HOLDING>). 17 See Payne v. Twiggs County School Dist.,
holding that to have standing a plaintiff must establish an injury in fact a casual connection between the injury and that the injury will be redressed by a favorable decision holding that to show a causal connection the plaintiff must demonstrate a relationship between the misconduct and the plaintiffs 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 there must be a causal connection between an insureds advertising and an alleged injury to trigger coverage for an advertising injury holding that there must be a causal connection between the advertising activity and the injury alleged in the underlying complaint