In our association, we are strict on language when anybody other than those in the immediate area can hear the language--regardless of the target of such language. For example, a kid missses a tackle then punches the ground and drops an F-bomb loud enough for the crowd to hear, it's a flag. On the other side, a kid points to his opponent and says "#$@! you, #33!" so only the nearby official hears it--it's a flag.
In your case, I would take into account how loud it was. If anybody outside of the huddle could hear it, I'd flag it. In either case, I'd tell the coach bad language is not to be used, and warn him he could get flagged for it.
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