III. Principles Surrounding the Duty to Defend
 The insuring agreement in the policies provides that
will pay those sums that the insured becomes legally obligated to pay
as damages because of “bodily injury” or “property damage” to which this
 For purposes of this motion, Northbridge concedes that
the damage at issue constitutes property damage but that it is
relieved of any duty to defend because of the exclusions in
 The motion therefore turns on the interpretation and
application of the exclusions and the duty to defend.
 The principles applicable to exclusions and the duty to
defend are not disputed. They can be summarized as follows:
(a) The onus is on the insurer to establish that an exclusion
applies: Poplawski v McGrimmon (2010), 100 O.R. (3d) 458,
 O.J. No. 33, 2010 ONSC 108 (S.C.J.), at para. 23.
(b) A policy exclusion will only relieve an insurer of a duty
to defend where coverage is necessarily and conclusively
excluded: Versa Fittings, at para. 61.
(c) An insurer has a duty to defend if there is a “mere possibility” that a claim falls within the coverage provided by the
insurance policy: Nichols v. American Home Assurance Co.,
 1 S.C.R. 801,  S.C.J. No. 33, at p. 810 S.C.R.
(d) The duty to defend is broader than the duty to indemnify:
Nichols, at p. 810 S.C.R.
(e) Whether an insurer is bound to defend a particular claim
will depend on an assessment of the allegations made in the
pleadings filed against the insured. This remains so even
though the actual facts may differ from the allegations
pleaded: Monenco Ltd. v. Commonwealth Insurance Co.,
 2 S.C.R. 699,  S.C.J. No. 50, at p. 713 S.C.R.
(f) The object of reading a pleading to determine whether it
triggers coverage is to focus on the pith and substance of the
pleading. “[T]he court needs to look beyond the labels and
assess what is really being alleged. This will often require
the application of common sense to an evaluation of what
has been pleaded”: Versa Fittings and Manufacturing Inc. v.
Berkeley Insurance Co.,  O.J. No. 1378, 2015 ONSC
1756 (S.C.J.), at para. 43.