In California Service Station etc. Assn. v. American Home Assurance Co. (1998) 62 Cal.App.4th 1166, the court held that a negligence cause of action against an insurer could not be based on a duty to disclose how the dividends on dividend-paying worker's compensation insurance would be calculated. (Id. at pp. 1173-1177.) In the course of doing so, it stated, "There is no duty of ordinary care to disclose pricing information during arm's-length contract negotiations." (Id. at p. 1173.) The court was careful to note, however, that the appellants had not pursued any type of cause of action for fraud (California Service Station etc. Assn. v. American Home Assurance Co., supra, 62 Cal.App.4th at p. 1172): "In fact, appellants actively disavowed any fraud, deceit or misrepresentation causes of action . . . . Of course, if they had made such claims they would have had to prove that respondent intended to induce them to market its policies by intentionally concealing dividend information, or by means of a positive misrepresentation that was either intentional or negligent. They would also have had to prove that they relied on the concealment or misrepresentations in agreeing to market respondent's policies. Appellants are not unsophisticated, and are represented by very able counsel, so the natural inference is that they were unable to muster such proof." (Ibid.) Thus, the court strongly suggested that a fraud cause of action could be based on a duty to disclose pricing information, as long as all the other elements of fraud were present.