A Florida federal court recently ruled that third-party beneficiaries under an insurance contract were not entitled to attorney fees under Fla. Stat. § 627.428 where they were not named in the insurance contract. In Conyers et al. v. Balboa Insurance Company, 2012 U.S. Dist. LEXIS 42340 (M.D. Fla., Mar. 26, 2013) (Hernandez Covington, J.),