for losses incurred as a consequence of the insurer's breach, such as lost business opportunities when money intended to be invested in those opportunities was diverted (or seized) to pay judgments. In the United States (and to a lesser extent, Canada), an insurer who breaches any of these three duties in a particularly egregious fashion may also be held liable for the tort of insurance bad faith, under which the insured may be able to recover compensatory damages in excess of the policy limits, as well as punitive damages. Occurrence v. claims-made policies Traditionally, liability insurance was written on an occurrence basis, meaning that the insurer agreed to defend and indemnify against any loss which allegedly "occurred" during the policy period as a result of an act or omission of the insured. This was originally not a problem because it was thought that insureds' tort liability was predictably limited by doctrines like proximate cause and statutes of limitations. In other words, it was thought that no sane plaintiffs' lawyer would sue in 1978 for a tortious act that allegedly caused a covered loss in 1953, because the risk of dismissal was so obvious. In the 1970s and 1980s, a large number of major toxic tort (primarily involving asbestos and diethylstilbestrol) and environmental liabilities resulted in numerous judicial decisions and statutes that radically extended the so-called "long tail" of vulnerable policies. Policyholders started to argue that losses began to occur not only at the time of a plaintiff's diagnosis or the belated discovery of underground pollution, but from the time a plaintiff received the first of many cumulative exposures to a toxic substance or when the defendant initially released pollutants, and that such losses continued to keep occurring through every subsequent policy period (though they did not ripen into lawsuits until much later). The result was that insurers who had long ago closed their books on policies written 20, 30, or 40 years earlier now found that their insureds were being hit with hundreds of thousands of lawsuits that potentially implicated those old policies. A body of law has developed concerning which policies must respond to these continuous injury or "long tail" claims, with many courts holding multiple policies may be implicated by the application of an exposure, continuous injury, or injury-in-fact trigger and others holding that only the policy in effect at the time the injuries or damages are discovered