Because the title insurance policy at issue stated clearly that the insurer owed a duty to defend only litigation, this decision holds that the insurer owed no duty to pay costs that the insured incurred during a period between the end of one covered action and the commencement of another covered action. Even though the insured incurred legal expense during the interim period, there was no litigation pending and so no duty to defend or pay the insured’s costs in the interim period.