SEC investigation, subpoenas not a “claim” 10th Circuit, Colorado (unpublished)

MusclePharm v. Liberty , involved an SEC investigation of MusclePharm.  The SEC issued subpoenas to some of MusclePharm’s people.  Summary judgment to Liberty was affirmed.  The SEC investigation was not a claim as defined in the policy.  The Tenth Circuit also denied motions to seal the records, and stated the bias towards open records.