Can a for-profit corporation be represented by an in-house attorney for the insured?

Third, subsequent cases have allowed corporations to represent not only their own interests, but third party interests, as well. See Frye v. Tenderloin Housing Clinic, Inc., 38 Cal. 4^th 23, 38-39 (2006) (affirming for profit and nonprofit corporations' ability to represent third party clients). Finally, subsequent cases have held that in-house attorneys of an insurance company can ethically represent the company's insured without the company being engaged in the practice of law. See Gafcon, 98 Cal. App. 4^th at 1396-97.