10.  In the settlement agreement for the Mfg Class Action, Mfg  purportedly assigned certain rights to the Class (Complaint ¶19).  Specifically,  Mfg assigned its rights under certain St. Paul insurance policies to the Class.   (A  copy of the settlement agreement is attached as Exhibit 3).    12.  The Court found, based on the settlement agreement, that Mfg sent  over 500,000 facsimile advertisements without prior express permission or  invitation during the class period.   13.  On January 24, 2014, following a fairness hearing, the court in the  Mfg Class Action entered an order granting final approval of the settlement  agreement and order for a judgment (“Judgment”).  (See Complaint, ¶20, Ex. J.)   The Judgment was in the amount of $22,536,500.  The Judgment stated at the  time of the Final Approval, Mfg had paid $75,000 of the Judgment and would  pay an additional $385,000.  The remainder of the Judgment ($22,076,500.00) was  to be satisfied only through Mfg’s primary and umbrella insurance policies from  St. Paul covering the period including January 17, 2005 through November 15,  2008.  (See Complaint ¶22, Ex. J, pp.7-8.)   15.  According to the State Court Action, G.M. Sign alleges that G.M.  Sign’s and the other Class members’ receipt of the junk faxes constitute property  damage under the St. Paul policies.  (See Complaint ¶ 39).  G.M. Sign also alleges  that “personal injury” coverage is triggered because the junk faxes to G.M. Sign  and the other Class members constitute making known covered material that  violates G.M. Sign’s and the Class members’ rights of privacy.  (See Complaint  ¶50).  G.M. Sign also alleges that “advertising injury” coverage is triggered  because Mfg’s transmission of unwanted faxes to Plaintiff and the other Class  members constituted making known covered material that violated Plaintiff’s  and Class members’ rights of privacy. (See Complaint ¶57).  G.M. Sign also  alleges that St. Paul was required to defend Mfg in the Mfg Class Action, did not  defend Mfg, and is estopped from asserting its policy defenses to avoid  satisfying the judgment entered in the Mfg Class Action.  (See Complaint ¶61.)     3.  The above-captioned case was filed in the Superior Court of Fulton  County, Georgia, on August 6, 2014, as case no. 2014CV249897 (the “State Court  Action”) and seeks relief on behalf of a certified class.     5.  Plaintiff states in its Complaint that G.M. Sign, Inc. is an Illinois  corporation with its principal place of business in Illinois (Complaint ¶4).  St.  Paul is a Connecticut insurance company with its principal place of business in  Connecticut.     6.  The Complaint asserts that G.M. Sign is bringing this action on  behalf of itself and other members of a certified class that it represents as the  judgment creditor and assignee of Mfg.com (“Mfg”) (See Introduction to  Complaint and Complaint ¶ 2).     8.  In the Mfg Class Action, Plaintiff, individually and as the  representative of a class, alleged that Mfg violated the Telephone Consumer  Protection Act, 47 U.S.C. § 227 et seq., and the Illinois Consumer Fraud Act, 815  ILCS 5/2-801, and common law conversion by sending unsolicited junk faxes to  Plaintiff and hundreds of others (Complaint, Ex. A).    9.  On September 27, 2013, the Lake County Circuit Court in the Mfg  Class Action certified a class of “all persons to whom Defendant sent advertising  facsimiles during the period January 17, 2005 through November 15, 2008  without their prior express invitation or permission.”  (See Complaint, ¶17, Ex.  I).  The order of September 27, 2013 also appointed G.M. Sign as the class  representative and Plaintiff’s counsel as class counsel.  (See Complaint, Ex. I, ¶3).  