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Insurers, working without legislative or judicial direction, created a  working definition of the term \\u201cactual cash value.\\u201d Insurers recognized that ACV in a fire insurance policy was designed to  establish a dollar value for items of destroyed property that were not  new at the time of loss. Since the insurers had no easy means to  establish the used value of property, they selected the following as  their working definition of \\u201cactual cash value\\u201d: \\u201cActual cash value is  the cost to replace with like kind and quality less physical  depreciation.\\u201d [Jefferson Insurance Company of N.Y. v. Superior Court, 3  Cal. 3d 398 (1970).]  The working definition, although it did not always provide the complete  indemnity contemplated by the insureds and by the various legislatures,  was eminently practical.