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In a game-changing decision, the Georgia Supreme Court eliminated bad-faith failure to settle cases absent a "valid offer" from the injured party. In First Acceptance, the Georgia Supreme Court ruled as follows:"We also asked the parties to address whether an insurer's duty to settle arises only when the injured party presents a valid offer to settle within the insured's policy limits or whether, even absent such an offer, a duty arises when the insurer knows or reasonably should know that settl