COVID-19 insurance litigation has steadily increased as policyholders seek recovery for their unprecedented losses arising from the pandemic and governmental orders. Across the country, courts continue to come down on opposite sides of the coin on whether COVID-19 constitutes "physical loss or damage" to property. Florida law is clear that ambiguity in the policy's language should be construed in favor of coverage. Given this clear requirement, courts should broadly construe coverage grants and strictly construe exclusions to resolve the dispute over what constitutes "physical loss or damage" in favor of policyholders. This is particularly true in light of the clearly reasonable alternative findings by multiple courts on this issue.