Mealey's (December 1, 2020, 10:45 AM EST) -- PHILADELPHIA — A federal judge in Pennsylvania on Nov. 23 held that because an underlying complaint fails to accuse an insured of making false statements about the underlying claimants' products, there is no claim of disparagement under Pennsylvania law “that is actually or potentially within the scope of the Policy to trigger a duty to defend” (Vitamin Energy, LLC v. Evanston Insurance Company, et al., No. 19-3672, E.D. Pa., 2020 U.S. Dist. LEXIS 218779)....