By Jan Larson and Jennifer Senior (June 7, 2017, 4:48 PM EDT) -- An appeal pending before the U.S. Court of Appeals for the Ninth Circuit in the case of HotChalk Inc. v. Scottsdale Insurance Co. is likely to shape the scope of professional services exclusions and determine whether they are so broad as to sweep in the types of allegations often brought against companies under the False Claims Act in connection with a company's interactions with the government or various government programs. Specifically, the Ninth Circuit's decision is expected to address the availability of coverage for claims relating to a policyholder's internal activities, such as compensation practices, that are arguably ancillary to the policyholder's external business practices or professional services provided to its clients and customers....