Travel Insurance Facilities, PLC v. Naples Community Hospital, Inc.
A Florida hospital sued UK/German travel insurers under assignments of benefits from foreign patients treated in Florida. The Sixth DCA reversed the denial of the insurers' motions to dismiss, holding the trial court's order was deficient for failing to make findings on the long-arm prong of Venetian Salami, and that in any event the insurers lacked minimum contacts because their only connection to Florida arose from insureds' unilateral travel and a website accessible in Florida but limited to UK residents.
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