In 2009, we noted that the Ninth Circuit rejected a California law that purported to permit lawsuits against insurers over the Ottoman genocide of Armenians. (That decision came too late for some insurers, who gave in to the legal extortion and funded cy pres slush funds that have since become the subject of collateral litigation.) Since then, California has renewed the law, permitting these suits to be brought until 2016, but last week, the Ninth Circuit, sitting en banc, unanimously reconfirmed its decision that the move was outside of appropriate insurance regulation.