Souter, Associate Justice (Ret.), sitting by designation. And Bill.
Given a more stringent parallel exclusion in the insurance policy, the more laconic exclusion creates an ambiguity sufficient to trigger the presumption for the insured and the resulting duty to defend.
http://media.ca1.uscourts.gov/pdf.opinions/17-1505P-01A.pdf
Since 2011. An occasional commonplacing of the U.S. Circuit Courts of Appeal.
Neither an authoritative statement of the law nor legal advice. Quick work.