 In some jurisdictions, like California, third party coverage also contains a third duty, the duty to settle a reasonably clear claim against the policyholder within policy limits, in order to avoid the risk that the policyholder may be hit with a judgment in excess of the value of the policy (which a plaintiff might then attempt to satisfy by writ of execution on the policyholder's assets).If the insurer breaches in bad faith its duties to defend, indemnify, and settle, it may be liable for the "entire" amount of any judgment obtained by a plaintiff against the policyholder, even if that amount is in excess of policy limits.This was the holding of the landmark "Comunale" case.