Cowan Liebowitz & Latman, P.C. v. Kaplan, 902 So. 2d 755 (Fla. 2005) was the first and only case in which the Court permitted a limited exception to the general prohibition on legal malpractice assignments, and our holding was confined to the specific facts and circumstances of that case. Specifically, Kaplan involved the following facts: "Medical Research Industries, Inc. (MRI), a Florida corporation, developed and marketed homeopathic medical products. To raise money for capital improvements, MRI decided to issue a private placement of shares in the company. MRI's majority shareholder, William Tishman, consulted attorneys who prepared private placement memoranda. Through four private placements between 1996 and 1998, MRI raised over $ 50 million from about 2000 shareholders. Later, Tishman borrowed about $ 18 million in unsecured loans from MRI, leading to its eventual insolvency. MRI sued Tishman to recover the loan amount and obtained a judgment. Unable to satisfy the judgment, however, MRI executed an "Assignment for the Benefit of Creditors" to Donald Kaplan. Kaplan then sued for legal malpractice the attorneys who prepared the private placement memoranda. The trial court granted the attorneys' motions to dismiss, concluding that legal malpractice claims are personal and not assignable and are exempt from levy and sale under an execution of assignment." (902 So. 2d at 757.) The trial court dismissed the action, concluding that legal malpractice actions are not assignable. On appeal, the Third District reversed, holding that the legal services at issue in Kaplan were not personal in nature but rather involved the publication of corporate information to third parties. Subsequently, the Court approved the Third District's holding and receded from "broad dicta" in Forgione and KPMG, which purported to prohibit the assignment of all legal malpractice claims. See Kaplan, 902 So. 2d at 757. In Kaplan, "the attorneys owed a duty to the public when advising MRI and preparing the private placement memoranda." Kaplan, 902 So. 2d at 761. The Court explained that attorneys preparing private (or public) placement memoranda "act not just for the corporation's benefit, but for the benefit of all those who rely on the representations in their documents--in this case, potential shareholders." Id. at 758 . The Court receded from the dicta in Forgione v. Dennis Pirtle Agency, Inc., 701 So. 2d 557 (Fla. 1997) prohibiting the assignment of all legal malpractice claims. 902 So. 2d at 757. While acknowledging that the vast majority of legal malpractice cases could not be assigned because of the personal relationship between attorney and client, we said that the legal service itself has to be examined to determine whether or not it is personal in nature. As to the particular facts of Cowan, the Court determined that the claims assigned did not "involve personal services or implicate confidentiality concerns." Id. at 761.