Solutions, Property & Casualty, Commercial Auto

Built in the ELD, not in court

Reptile-theory discovery has rebuilt commercial-auto litigation around hours-of-service, following-distance and CSA scores. The carriers losing are the ones who do not pull telematics until day sixty. Owl reads the ELD, the dashcam, the dispatch log and the FMCSA record on intake, synced to the second.

Telematics, Unit #FL-22842025-07-31, 16:42, 10 min
HOS log, day of loss
ELD, 9.2 hrs driving
+42m
Paper logs, 8.5 hrs driving
Following distance, seconds
1.5s, plaintiff-bar thresholdIMPACT

42 min

HOS gap, ELD vs. paper logs

<1.5s, 8 of 10

Following distance below threshold

BASIC: 4 / 7

CSA SMS Unsafe Driving + HOS flagged

03A real claim, walked end to end

One loss: a 42-minute HOS gap, 8 minutes under 1.5s following distance, a $4.2M demand.

Anonymized composite: Class 8 tractor-trailer, rear-impact on I-44, two claimants. Demand received 9 weeks post-DOL alleging spinal injury, lost earnings and “egregious safety practices.”

Claim #
CA-2025-07-30221
LOB
Commercial Auto, Class 8
DOL
2025-07-31, 16:42
Demand
$4,200,000
Reserve (Owl)
$1,840,000
OwlVision
What it read
ELD + telematics export (Geotab)
1 pp
Read, Indexed, Cited
Paper logs, 30 days
36 pp
Read, Discrepancy flagged
Dashcam (forward + cabin), 90s
1 pp
Read, Time-synced
Police report + 911 audio
14 pp
Read, Indexed, Cited
Demand letter + medical specials
84 pp
Read, Allegation graph
Structured extraction
DOL 2025-07-31 16:42, I-44 EB MM 218. Rear-impact on stopped traffic queue. ELD: 9.2 hrs driving day of loss vs. 8.5 hrs paper logs (42-min discrepancy). Following distance <1.5s for 8 of preceding 10 minutes. No braking input until 0.6s pre-impact. Weigh station bypass 14:32. Dispatch dispatched run 02:48 (12hr+ pre-DOL). MCS-90 endorsement on certificate. Two BI claimants.
OwlSignal
What the world said about the claimant

External data only. None of this lives in your CMS. Owl gathered it from public records, professional networks, registries and the open web, then resolved it to this claimant.

HOS-01
HOS, ELD + paper-log compare

FMCSA-pulled ELD shows 9.2 hrs driving day of loss; paper logs show 8.5 hrs, a 42-minute discrepancy. Carrier weekly cap exceeded by 1.4 hrs in the preceding 8-day cycle. Falsification doctrine exposure on §395.8(e). Dispatcher chat (preserved on Samsara) shows pressure to make delivery window.

FMCSA ELD pullPaper-log scanSamsara dispatcher chat49 CFR §395.8
TEL-02
Following distance, telematics

Geotab telematics shows <1.5s following distance for 8 of preceding 10 minutes. Plaintiff-side discovery target. No braking input until 0.6s pre-impact (Bendix Wingman ADAS event log). Carrier-fleet driver score for unit operator is in the 22nd percentile across the fleet for distance-keeping over 90 days.

Geotab telematicsBendix Wingman ADASCarrier fleet driver-score
CSA-04
FMCSA SAFER + CSA SMS BASIC

Carrier USDOT 2,148,xxx. CSA SMS percentile alerts on Unsafe Driving (78th) and HOS Compliance (82nd) BASICs. Three roadside inspections in last 24mo with HOS violations on this unit. Two prior crashes on the SAFER record (one PD, one BI).

FMCSA SAFERCSA SMS BASICsRoadside inspection recordsPSP crash history
MVR-02
Driver MVR + PSP, prior-employer

Driver MVR (with PSP consent) shows two moving violations in last 36mo (one careless driving, one following-too-close). Prior-employer pull (3 years) shows separation from a prior carrier within 90 days of a preventable rear-end. Negligent-entrustment exposure if hire-process documentation is thin.

State MVR, 3yrFMCSA PSP reportPrior-employer §391.23
ADV-02
Plaintiff counsel, nuclear-verdict pattern

Counsel has 8 commercial-MV verdicts > $5M in the last 60 months in this venue. Three on similar fact patterns (rear-impact, HOS issue, ADAS data). Demand-letter language fingerprint matches 4 prior cases that resolved at $1.6M – $2.2M when full ADAS + ELD data was produced day-30.

Jury Verdict ReporterPACER + state e-courtDemand-letter fingerprint
OwlAssist
What it answered
Examiner asked
What is our exposure given the HOS discrepancy and following-distance data?
Owl answered in 1.5s

Material exposure. The 42-minute HOS discrepancy on the day of loss combined with 8 minutes of <1.5s following distance preceding the collision creates a negligence-per-se argument under 49 CFR §395 plus a reptile-theory safety-rules theme that this venue’s plaintiff bar runs effectively. ADAS Bendix Wingman log shows no braking until 0.6s pre-impact. Recommended initial reserve: $1.84M against $4.2M demand, with $750K floor and $2.4M ceiling depending on contributory of lead claimant. Preserve ELD, ADAS, dispatcher chat and dashcam under formal litigation hold today; spoliation is the loser here, not liability. MCS-90 endorsement on certificate but inapplicable to BI in non-interstate-cargo theory.

ELD 2025-07-31 driving-time49 CFR §395.8(e)Bendix Wingman 16:41:54–16:42:00Demand pp.4–11
Examiner asked
Run the negligent-entrustment analysis.
Owl answered in 1.1s

Defensible but not dismissable. Driver hire 2024-03 included §391.23 prior-employer pulls, road test and §391.21 application: process is documented. PSP report at hire is in file. However: MVR at hire showed one prior moving violation; second violation accrued 2024-11 (post-hire) and was not flagged because the carrier’s annual MVR re-pull (§391.25) was performed late on 2025-04 (4 months past anniversary). That gap is the negligent-supervision angle counsel will work. Recommended pivot: stipulate to vicarious liability to moot negligent-entrustment claim; contest comparative fault on lead claimant, who was 14mph below posted in left lane (Geotab on lead vehicle pulled via LexisNexis Telematics Exchange).

§391.21 hire packet§391.23 prior-employer§391.25 annual MVR (late)LexisNexis Telematics Exchange, lead vehicle
04OwlSignal external data

What the world says about your Commercial Auto claimants, none of which lives in your CMS.

Internal claim data is half the picture: it tells you what the claimant told you. OwlSignal continuously gathers external data (public records, professional and corporate registries, court dockets, social and open web) and matches it back to the claimant. These are the families that move the needle on Commercial Auto.

TELTelematics & ADAS

Carrier-fleet telematics (Geotab, Samsara, Lytx, Omnitracs), ADAS event logs (Bendix Wingman, Mobileye), ELD exports, weigh-station bypass data, dispatcher chat: synced to the second against police and dashcam.

Geotab, Samsara, Lytx, OmnitracsBendix Wingman, Mobileye ADASFMCSA ELD pullWeigh-station bypass
CSAFMCSA & CSA

FMCSA SAFER carrier records, CSA SMS BASIC percentiles, roadside inspection history, PSP crash + inspection record, USDOT operating-authority status: the public-record carrier-safety profile.

FMCSA SAFERCSA SMS BASICsRoadside inspectionsFMCSA PSP
MVRDriver Records

State MVR pulls, FMCSA PSP reports, CDL status, drug-and-alcohol clearinghouse, prior-employer §391.23 pulls: what the driver record actually says, refreshed against the carrier’s annual cycle.

State MVR, 3yr / 7yrFMCSA PSPFMCSA Drug & Alcohol ClearinghousePrior-employer §391.23
ADVPlaintiff Counsel & Verdict Patterns

Plaintiff-bar matter history, nuclear-verdict patterns by venue, demand-letter fingerprinting, jurisdictional verdict-history graphs: the data on the other side that decides reserve and authority.

Jury Verdict ReporterPACER + state e-courtVerdict-pattern graphsDemand-letter fingerprint
PEXPre-existing Conditions

External EHR pulls and HL7 exchanges that surface diagnoses, treatments and pain-management history the demand letter does not disclose. Reframes apportionment from a debate to a documented fact pattern.

DatavantMRO, Verisma, CioxHL7 records exchangePharmacy fill history
WAGWage & Income Records

IRS 4506-T income reconstruction, state UI wage records, 1099 reconciliation, employer payroll filings. Closes the gap between claimed wage-loss and substantiated earning capacity.

IRS 4506-TState UI wage recordsEmployer payroll filings1099 cross-check
Refreshed daily, matched by identity-resolution, every observation cited to its source.
05What changes

Numbers from P&C carriers running Owl on Commercial Auto in production.

MetricWithout OwlWith Owl
Telematics evidence at first reserve8%94%
Nuclear-verdict exposure caught early34%88%
HOS / ELD discrepancy detection22%81%
Spoliation hold issued day-712%92%
Avg cycle to authority decision54 days14 days
Indemnity leakage per claim$8,400$2,200
Source: rolling 12-month average across 4 P&C carriers, Commercial Auto only, n = 24,200 claims.

Built for the regulatory shape of Commercial Auto.

UCSPA, NAICUnfair Claims Settlement Practices: every Owl-assisted decision cited and auditable.
State DOI examAudit trail per claim, per touch, per citation. Export to your DOI format.
MCS-90 + filingsMCS-90 endorsement logic, Form-E / Form-K state filings, federal motor-carrier compliance built in.
Spoliation / litigation holdAutomatic preservation triggers on ELD, ADAS, dashcam and dispatcher-chat artifacts. Hold notice templated and logged.
FCRA-aware sourcingEvery external observation flags FCRA-permissible-purpose status. PSP / MVR pulls under driver consent.
Reg AI / NYDFSBias testing, model documentation, human-in-the-loop on every adverse decision.
SOC 2 Type IIAnnual audit. Continuous controls monitoring. Report available under NDA.
Records retentionConfigurable per state, per LOB, per carrier policy.
07Integrations

Lives where your Commercial Auto files live.

Claim systems

Guidewire ClaimCenter, Duck Creek, Origami, Ventiv, in-house

Telematics

Geotab, Samsara, Lytx, Omnitracs, LexisNexis Telematics Exchange

Estimating

CCC ONE, Mitchell, Audatex, Truck Pro Sims

FMCSA / CSA

SAFER, CSA SMS, PSP, D&A Clearinghouse, §391.23

Document intake

Box, OnBase, Documentum, ImageRight, Kofax

Identity & SSO

Okta, Azure AD, PingFederate, SAML, SCIM provisioning

08Get started

Bring us a closed Commercial Auto file. We’ll show you the ELD, the ADAS and the verdict pattern you missed.

Two-week pilot. Your records, your tenant, your fleet partners. We measure cycle time, reserve accuracy, spoliation-hold timing and nuclear-verdict catch against your own ground truth.