Read the following excerpt from a US court opinion:
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first publication took place before the beginning of the policy period.... The policy defines “personal injury” as injury, other than "bodily injury," arising out of one or more of the following offenses: d. Oral or written publication of material that slanders or libels a person or organization or disparages a person's or organization’s goods, products or services; or e. Oral or written publication of material that violates a person’s right of privacy. “Advertising injury” is defined as: injury arising out of one or more of the following offenses: a. Oral or written publication of material that slanders or libels a person or organization or disparages a person's or organization’s goods, products or services; b. Oral or written publication of mate 8 Pa.Super. 326, 614 A.2d 295 (1992) . 8 . The insurer’s unjustified refusal to
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What is the most suitable continuation to the opinion? Your options are:
A. holding that the trial court erred in looking beyond the allegations of the complaint to determine whether a duty to defend arose
B. holding that attorneys fees can be awarded only from time duty to defend arose
C. holding that awarded fees were reasonable and that proof that attorneys fees are necessary apart from testimony as to the reasonableness of the fee is not required
D. holding that a thirdparty claimant could be awarded attorneys fees and penalties pursuant to  221220 because the insurers failure to defend was arbitrary and capricious
E. holding that insurer had a continuing duty to defend
Reply with [A, B, C, D, E] only.