In Nutmeg Securities, Ltd. v. McGladrey & Pullen (2001) 92 Cal.App.4th 1435, the court held that a corporation's accountant had a duty to the corporation's underwriter of its initial public offering because the accountant "prepared the financial statements it reviewed" and participated in creating the false financial statements. (Id. at p. 1443.) The court determined that the Bily analysis did not apply because the accountant's role was "not 'secondary,' but primary." (Nutmeg Securities, at p. 1443.)