The Eleventh Circuit recently affirmed the Southern District of Florida’s dismissal of a policyholder’s $5 million putative class action lawsuit against the nation’s third largest private passenger insurer. The plaintiff alleged that Geico violated the terms of his insurance policy through its practice of applying “betterment adjustments,” through which Geico reduces the amount paid to a policyholder when repairs increase the value of a vehicle. The district court found the language of the policy’s betterment adjustment provision unambiguous.