Grimberg sold a famous painting to Cohen for $785,000. Possession of the painting passed to Cohen but payment was never made. Despite various and sundry attempts to resolve the issue, Grimberg never received payment or got the painting back. Cohen was subsequently convicted of fraud. Grim- berg filed an insurance claim with his insurance company, which denied payment since, it claimed, Grimberg had transfer red title to Cohen. Grimberg claimed that he transfer red a voidable title and thus still retained an insurable interest in the painting. Who won?