In the Ultramares Corp. v. Touche (1931) case, the court established a test to hold a professional liable to third party non-clients for negligence in the preparation of financial reports in certain limited circumstances. Under this Ultramares case, all of the following are required, except:

the third party non-client must have a familial relationship with the client.

the professional must know the name of the intended non-client who will use the financial reports.

the professional must know the purpose of the financial reports.

the professional must know the extent of the use of the financial reports.