In LaSalle National Bank v. Ernst & Young LLP, (285 A.D.2d 101 [1st Dept 2001]), the Appellate Division reversed the lower court's denial of Ernst & Young's pre-answer motion to dismiss the plaintiff's causes of action sounding in, among other things, negligence, in connection with accounting services that Ernst & Young provided to its client, non-party Kent International Associates, Ltd. The First Department reasoned: In order to impose negligence liability on an accountant for injury to a non-contracting third party resulting from the accountant's advice or services, the third party must establish each prong of the Credit Alliance test, that is: [1] the accountant's awareness that the financial reports were to be used for a particular purpose or purposes; [2] reliance on the reports by a known party or parties; [3] some linking conduct on the part of the accountant which evinced the accountant's understanding regarding the third party's reliance. These requirements . . . must be distinctly pleaded and,. . . since we review a CPLR 3211 motion to dismiss on the pleadings . . . the standard guiding us is whether the allegations in the complaint, construed liberally, satisfy each of these three requirements. Although we focus here on the pleadings, the pleadings still must establish a basis of liability arising from either actual privity or contract between the parties or a relationship so close as to approach that of privity requiring a clearly defined set of circumstances which bespeak a close relationship premised on knowing reliance (id. at 105-106).