The United States Court of Appeals for the Eleventh Circuit, applying Florida law, has held that an insurer did not need to cover underlying litigation instituted against its insured during the policy period because related pre-suit demands constituted “claims” made before the policy incepted. Certain Underwriters at Lloyds, London v. Anchor Ins. Holdings, Inc., 2024 WL 4836693 (11th Cir. Nov. 20, 2024). The appellate court did not reach the question of whether the insurer had a right to rescind the policy, which was the basis for the trial court’s ruling.