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4448 The threshold requirement for recovery under a contract of property insurance is that the insured property has sustained physical loss or damage, so in the absence of physical damage to property, a policy that covered property damage caused by employee dishonesty did not cover amounts the insured paid to settle litigation against it arising from a conspiracy by some of its employees to fix a contest it was running for a client, or losses resulting from the insured's going out of business as a result.CitationSIMON MARKETING v GULF INS (Employee Dishonesty) 149 CA4 616 [See: Vons v Federal Ins 212 F3 489; Lynch v Potomac Ins 140 F3 622; Alberts v American Cas 88 CA2 891]
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