What constitutes a material misrepresentation in the context of an insurance claim?

California law provides that an insurer may deny a claim or void a policy if an insured knowingly, intentionally, and with the intent to defraud misrepresents or conceals a material fact during the presentation of the insurance claim. Cummings v. Fire Ins. Exch., 202 Cal.App.3d 1407, 1414-17, 249 Cal.Rptr. 568 (1988) (affirming summary judgment for insurer because insured made material misrepresentations during presentation of claim). "[M]ateriality is determined by its prospective reasonable relevance to the insurer's inquiry." Id. at 1417. Thus, a misrepresentation is material if it "concerns a subject reasonably relevant to the insured's investigation, and if a reasonable insurer would attach importance to the fact misrepresented." Id. The "intent to defraud the insurer is necessarily implied when the misrepresentation is material and the insured wilfully makes it with knowledge of its falsity." Id. at 1418.