Possibly. In State Farm Fire & Cas. Co. v. Trumble, 663 F. Supp. 317, 320 (D. Idaho 1987), the court stated: "The bad faith claim takes into account all of the activities of the insurer, including the filing of the declaratory judgment action, in an attempt to prove that there is no reasonable basis for denying the benefits of the policy and that the [insurer] had knowledge or reckless disregard in obtaining the knowledge of the lack of a reasonable basis for denying the claim."


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