Like the rest of the world, the U.K. and the U.S. have each been ravaged by the COVID-19 pandemic — illnesses, deaths, business closures, lockdowns, economic downturns and spikes in unemployment.

Not surprisingly, there has been a massive number of insurance claims by businesses impacted by forced closures, government orders and dramatic reductions in consumer confidence, consumption and economic activity. In general, the insurance industry has responded to these claims with skepticism. The hallmark of property damage/business interruption insurance has historically been “direct physical loss or damage.” But the responses of the insurance industry, government and the courts in the two countries have been dramatically different, even though the countries have a common language and historically related legal systems.

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