In In re CitX Corp., 448 F.3d 672 (3d Cir. 2006), Detweiler, Hershey and Associates and Robert Schoen, CPA (the accounting firm) compiled the financial statements for an internet company that subsequently filed for bankruptcy. The financial statements were used to attract additional investors. Id., 448 F.3d at 674. As a result of the financial statements, new investment flowed into the company. However, the money flowed out more quickly than it flowed in, resulting in the company incurring millions in debt, and ending with a declaration of bankruptcy. Seitz, the trustee in bankruptcy, tiled an action against the accounting firm alleging malpractice and deepening insolvency. Id. The Third Circuit affirmed the district court's grant of summary judgment in favor of the accounting firm, finding that the trustee's evidence was based largely upon a false affidavit given by the company's chief operating officer. The Third Circuit concluded that deepening insolvency was not a "valid theory of damages for an independent cause of action." CitX Corp., 448 F.3d at 677.