In Sphinx International, Inc. v. National Union Fire Ins. Co. of Pittsburgh, PA, No. 03-13214, 2005 WL 1389234 (June 14, 2005), the Eleventh Circuit Court of Appeals ruled that an insured vs. insured exclusion in a directors and officers (D&O) insurance policy applied when a former director and officer filed suit against Sphinx International.

George Taylor was a director and an officer with Sphinx International and owned 10 percent of Sphinx's shares. He was fired when Sphinx learned he had not disclosed a covenant not to compete from his former employer and because he misrepresented his qualifications.