Extract to table

To the extent that the phrase "should be repaired, rebuilt, or replaced with reasonable speed and similar quality" is ambiguous as to the precise duration of the period of restoration in any given case — and it is inherently fact-dependent and thus susceptible to differing interpretations — that ambiguity must be resolved in VHG's favor

" This is an inherently fact-intensive inquiry that must be resolved on a case-by-case basis

The insured is not required to prove that its restoration timeline was the shortest possible; rather, the insurer must come forward with evidence demonstrating that the insured engaged in unreasonable delay

Florida courts have addressed the issue of whether an insured is required to operate portions of a damaged property on a partial basis during ongoing repairs

Courts held that it was unreasonable for insurers to measure the insured's restoration timeline against benchmarks applicable to non-catastrophic losses and that the period of restoration must account for the systemic disruptions caused by the catastrophe

These out-of-state authorities collectively reinforce the principle that post-catastrophe restoration timelines must be evaluated in the context of the specific catastrophe and its regional impacts, not against abstract benchmarks developed in the context of isolated losses