e. Cornhusker did not violate IFCA IFCA establishes a cause of action for “[a]ny first party claimant to a policy of insurance who is unreasonably denied a claim for coverage or a payment of benefits.” RCW 48.30.015(1). Defendants appear to concede that Cornhusker has not “denied a claim for coverage or a payment of benefits” in the traditional sense. {See Def. Mot. at 21-23.) They assert, however, that Cornhusker’s alleged violations of the Washington insurance regulations listed in subsection (5) of IFCA constitute a violation of IFCA, and that Cornhusker denied payment of benefits within the meaning of IFCA when Cornhusker offered an unreasonably low amount to settle the Contractor Suit. {Id. (citing Langley v. GEICO Gen. Ins. Co., 89 F.Supp.3d 1083, 1090-92 (E.D.Wash.2015) (<HOLDING>); Morella v. Safeco Ins. Co. of Ill., No.
holding that a violation of washington insurance regulations is not a violation of ifca and collecting cases holding that in order to maintain a derivative cause of action a shareholder must maintain a continuous ownership interest in the corporation recognizing the cause of action recognizing cause of action holding that an insured may maintain a cause of action under ifca for a violation of a washington insurance regulation listed in subsection 5 of ifca