In PF Sunset View, LLC v. Atlantic Specialty Insurance Company, Case No. 21-11580 (11th Cir. June 2, 2022), the Eleventh Circuit reiterated that there is no coverage for losses incurred from COVID-19 related business interruptions. The plaintiffs, four franchisees of Planet Fitness gym locations in Florida, sought damages from their insurance company for business income loss and extra expenses incurred as the result of closure orders. Relying on its recent decision SA Palm Beach, LLC v. Certain Underwriters at Lloyd’s of London, 32 F.4th 1347, 1350 (11th Cir. 2022), the Court held that the claims were properly denied because losses from the suspension of business operations and extra expenses incurred as a result of COVID-19 closure orders did not constitute tangible alterations to the insured property. Read more here.