In Small v. Fritz Companies, Inc. (2003) 30 Cal.4th 167, the Supreme Court held that the pleading standard for negligent misrepresentation in an action for securities fraud brought by a shareholder should adhere to the same heightened pleading standard as fraud due to the risk of false claims in such suits. In doing so, the high court first recognized the guiding policy behind requiring specificity in pleading fraud allegations: "Ideally, what is needed is some device to separate meritorious and nonmeritorious cases, if possible in advance of trial. California's requirement for specific pleading in fraud cases serves that purpose. 'In California, fraud must be pled specifically; general and conclusory allegations do not suffice. "Thus '"the policy of liberal construction of the pleadings . . . will not ordinarily be invoked to sustain a pleading defective in any material respect."' This particularity requirement necessitates pleading facts which 'show how, when, where, to whom, and by what means the representations were tendered.'" (Ibid.) Recognizing that no California court had thus far held that the specific pleading requirement applies to negligent misrepresentation actions, the Small court held it applies to a shareholder's action for negligent misrepresentation. (Small v. Fritz Companies, Inc., supra, 30 Cal.4th at pp. 184.) In so holding, the Supreme Court suggested that, if squarely presented with the issue, it might hold that the specific pleading requirement applies in other negligent misrepresentation actions as well.