Following the Illinois Supreme Court’s 2021 ruling in West Bend Mutual Insurance Co. v. Krishna Schaumburg Tan, Inc., 2021 IL 125978, which we covered in detail, a Chicago-based federal court recently handed another insurance coverage victory to businesses facing class actions under the Illinois Biometric Information Privacy Act (BIPA). The U.S. District Court for the Northern District of Illinois found that a general liability (GL) insurer had to defend its policyholders against two class action lawsuits alleging that the policyholders were selling biometric data in violation of BIPA and common law rights.