Under a manuscript endorsement, Yahoo’s insurance policy provided covereage for “injury . . . arising out of . . . [o]ral or written publication, in any manner, of material that violates a person’s right of privacy.”  This decision holds that the “restrictive relative phrase” “that violates a person’s right of privacy” might under standard rules of English usage and the judicial rule of last antecedent refer either to the closest preceding noun, “material,” or to the closest preceding phrase “publication, in any manner, of material.”  Under the former interpretation, the policy would cover only violations of the privacy right of secrecy–i.e., non-disclosure of private facts.  Under the latter interpretation, the policy also covers invasions of the privacy right of seclusion, making the manner of publication, rather than its content, the violation of privacy rights–and so under this interpretation, the policy covers TCPA claims.  The decision concludes that standard rules of interpretation do not resolve the ambiguity.  So unless there is evidence to show thata the insured did not reasonably expect that coverage, the insured is entitled to the broader coverage under the construction against drafter rule which applies here even though it is a manuscript endorsement because it adopts standard insurer-industry-drafted language.