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Inspirato LLC v. Ciafone
Citation: 274 So. 3d 487Docket: No. 3D18-355
Court: District Court of Appeal of Florida; May 29, 2019; Florida; State Appellate Court
Affirmation of the trial court's decision regarding a third-party beneficiary's breach of contract claim was upheld. A valid cause of action requires four key elements: 1) existence of a contract, 2) clear intent from the contracting parties to benefit the third party directly, 3) breach of the contract by one of the parties, and 4) resultant damages to the third party. Additionally, a non-party can only be deemed a specifically intended beneficiary if the contract explicitly states that it primarily and directly benefits them or a defined group to which they belong. The court referenced prior cases, affirming the dismissal of a claim where the attached contract did not demonstrate an intent to substantially benefit the alleged third-party beneficiary.