In Robinson Helicopter Co., Inc. v. Dana Corp. (2004) 34 Cal.4th 979, a contractor supplied components for its helicopters that did not comply with precise specifications approved by the Federal Aviation Administration (FAA). (Robinson Helicopter, supra, 34 Cal.4th at pp. 985-986.) The contract obligated the contractor to supply Robinson Helicopter with components that conformed to these precise specifications. (Ibid.) The contractor, nevertheless, provided intentionally false conformance certificates when it supplied these components. (Id. at p. 986.) Robinson Helicopter had to recall the affected helicopters with these components and explain the situation to federal and foreign regulators. (Id. at pp. 986-987.) The Robinson Helicopter court held the knowingly false certificates were fraudulent misrepresentations independent of the contractor's contractual duty. (Robinson Helicopter, supra, 34 Cal.4th at pp. 990-991.) Specifically, providing the nonconforming components breached the contract, but providing knowingly false certificates was "independent fraudulent conduct" that breached an independent tort duty. (Id. at p. 991.) The Robinson Helicopter court, however, did not rest its exception solely on extraneous fraud in the false certificates: "Our holding today is narrow in scope and limited to a defendant's affirmative misrepresentations on which a plaintiff relies and which expose a plaintiff to liability for personal damages independent of the plaintiff's economic loss." (Id. at p. 993, italics added.) Thus, Robinson Helicopter is limited to those circumstances when the tortious conduct is both separate from the breach of contract and caused damages independent of the contractual breach. (Id. at pp. 989-991.) In these narrow circumstances, the Robinson Helicopter court recognized a cause of action for fraud based on events that occurred after contract formation. (Id. at p. 991.)