For years, creative noninsured entities and individuals have concocted innovative ways to recover payment under homeowners policies to which they are not a party. Many times, the noninsureds have relied on obtaining assignment of benefits (AOBs) from the insureds to then recover payment. But, as a recent case from the U.S. District Court for the Eastern District of Pennsylvania shows us, noninsureds may pursue other options if that avenue is closed to them.