Common-law liability for fraud is available to third parties in any jurisdiction. The plaintiff (third party) must prove
a false representation by the accountant,
knowledge or belief by the accountant that the representation was false,
that the accountant intended to induce the third party to rely on false representation,
that the third party relied on the false representation, and,
that the third party suffered damages.
Liability for Fraudulent Misrepresentation
One who makes a fraudulent misrepresentation is subject to liability to the persons or class of persons whom he intends or has reason to expect to act or to refrain from action in reliance upon the misrepresentation, for pecuniary loss suffered by them through their justifiable reliance in the type of transaction in which he intends or has reason to expect their conduct to be influenced.
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