Back in the day, policyholders and insurers (and maybe everyone) understood what war was. War was a military action between government forces of sovereign nations. Today, not so much. With the proliferation of terrorism and armed groups controlling various jurisdictions like pseudo-governments, it is often difficult to know when an attack is war or terrorism. Insurers who cover risks operating in volatile regions often add war exclusions to their policies. The question the 9th Circuit Court of Appeals had recently was whether the war exclusions contained in a television production insurance policy precluded coverage when a production was delayed and then moved from its original location in Israel because of Hamas rocket attacks.