The interchangeable use of undefined modifier phrases (“arising out of,” “based on,” etc.) has required courts to consider whether, based on the interpretation of those modifiers, an exclusion potentially applies as a bar to coverage for a particular claim.  The exclusions found in general liability (“CGL”) policies are virtually always preceded by a preamble that there is no coverage “because of,” “arising out of,” or “based on” each of those enumerated exclusions. The interchangeable use of these undefined modifier phrases has required courts around the country to consider whether, based on the interpretation of those modifiers, an exclusion potentially applies as a bar to coverage for a particular claim.  Read full article at link below.

https://www.law.com/njlawjournal/2019/07/25/whats-in-a-modifier-how-insurance-policy-exclusions-are-interpreted-in-nj/