In a significant win for policyholders, the Ninth Circuit rejected an insurerâ€™s argument that the common meaning of â€œwarâ€ applied when interpreting a war exclusion, instead of the customary usage of the term, pursuant to Cal. Â Civ. Code 1644, and revived NBC Universalâ€™s attempt to recover at least $6.9 million in costs incurred to relocate the production of a television show from Jerusalem during the 2014 Israeli-Palestinian conflict. Universal Cable Prods., et al., LLC v. Atl. Specialty Ins. Co., 2019 WL 3049034, at *10 (9th Cir. July 12, 2019).