Is there "no real possibility" that the insured can be held liable for damages when an action is frivolous or meritless?

4 Similarly, there is "no real possibility" that the insured could be held liable for damages when an action is frivolous or meritless, or the allegations in the complaint are false. Nevertheless, the duty to defend, being far broader than the duty to pay, exists in such cases. See First Ins. Co. of Hawaii v. State, 66 Haw. 413, 665 P.2d 648, 652-53 (1983) (an insurer's duty to defend is construed liberally, and may extend to actions which are groundless, false or fraudulent).