In Linden Partners v. Wilshire Linden Associates (1998) 62 Cal.App.4th 508, the defendant seller prepared and "put" into escrow an estoppel certificate for an uncooperative subtenant showing a specified monthly rental, which turned out to be incorrect. The plaintiff buyer did not sue the subtenant, but instead sued the seller on the ground the seller had been required by the terms of the transaction to supply correct information about all tenants, including the rent paid. (Id. at pp. 512-514.) A jury rejected the buyer's tort claims, but found the seller had breached its contract with the buyer and awarded as damages the difference between the rent the subtenant actually paid and the greater amount the seller had incorrectly set forth in the estoppel certificate. (Id. at p. 515.) The Court of Appeal affirmed, rejecting the seller's arguments that the buyer had not relied on the estoppel certificate and the jury had not been correctly instructed on causation. (Id. at pp. 524-532.) In doing so, the court repeatedly noted the importance of the estoppel certificate to the buyer and observed the buyer "had every right to rely upon" the information set forth therein. (Id. at pp. 527, 529-530, 532.)