In Tunkl v. Regents of University of California (1963) 60 Cal.2d 92, a case arising under the more general contract provisions of Civil Code section 1668, the Supreme Court considered the validity of a release from liability for future negligence imposed as a condition for admission to the University of California Los Angeles Medical Center, a charitable research hospital. (Tunkl, supra, 60 Cal. 2d at p. 94.) It concluded that "an agreement between a hospital and an entering patient affects the public interest and that, in consequence, the exculpatory provision included within it must be invalid under Civil Code section 1668." (Ibid.) The Supreme Court described the types of transactions that involve the public interest. An "attempted but invalid exemption involves a transaction which exhibits some or all of the following characteristics. It concerns a business of a type generally thought suitable for public regulation. The party seeking exculpation is engaged in performing a service of great importance to the public, which is often a matter of practical necessity for some members of the public. The party holds himself out as willing to perform this service for any member of the public who seeks it, or at least for any member coming within certain established standards. As a result of the essential nature of the service, in the economic setting of the transaction, the party invoking exculpation possesses a decisive advantage of bargaining strength against any member of the public who seeks his services. In exercising a superior bargaining power the party confronts the public with a standardized adhesion contract of exculpation, and makes no provision whereby a purchaser may pay additional reasonable fees and obtain protection against negligence. Finally, as a result of the transaction, the person or property of the purchaser is placed under the control of the seller, subject to the risk of carelessness by the seller or his agents." (Id. at pp. 98-101) The Supreme Court was concerned with the validity of a release from liability for future negligence in a contract between a hospital and an entering patient. It held that such an exculpatory provision is invalid under section 1668 if it affects the public interest, and set out specific factors which constitute the public interest. (60 Cal.2d at pp. 98-101.) Tunkl did not address and does not affect the prohibition in section 1668 against a contract which purports to exempt a party from liability for his or her own fraud.