In Jones v. Aetna Casualty & Sur. Co. (1994) 26 Cal.App.4th 1717, in affirming a judgment in favor of the insurer, the Court of Appeal was unpersuaded by a lessee's argument that he had standing to prosecute a bad faith case as a third-party beneficiary of his landlord's insurance policy: "An insurer's duty of good faith and fair dealing is owed solely to its insured and, perhaps, any express beneficiary of the insurance policy. Incidental or remote beneficiaries of the policy cannot state a cause of action against the insurer for a breach of the duty. "It is apparent from the terms of the insurance policy in the instant case that Jones was not an intended beneficiary. The fact that, by virtue of the lease provision for rent abatement, Jones would have received some benefit in the event Aetna indemnified the lessor for loss of rental income only makes him an incidental beneficiary under the policy. The policy itself and surrounding circumstances do not demonstrate that Aetna and lessor intended Jones to benefit from their agreement. "The implied covenant of good faith and fair dealing in the insurance policy at issue was intended to benefit the insured lessor. Jones has no standing as a third party beneficiary to enforce the covenant made for the benefit of the lessor." (Jones, supra, 26 Cal.App.4th at pp. 1724-1725.)