In Pennsylvania, the cause of action for negligent infliction of emotional distress has been limited by court decisions. In order to recover, the Plaintiff must prove one of four elements: (1) that the Defendant had a contractual or fiduciary duty toward him; (2) that Plaintiff suffered a physical impact; (3) that Plaintiff was in a "zone of danger" and at risk of an immediate physical injury; (4) that Plaintiff had a contemporaneous perception of tortious injury to a close relative. See: Brown v. Philadelphia College of Osteopathic Medicine, 449 Pa. Super. 667, 674 A.2d 1130 (Pa.Super. 1996); Fewell v. Besner, 444 Pa. Super. 559, 664 A.2d 577, 581 (Pa.Super. 1995); Armstrong v. Paoli Memorial Hospital, 430 Pa. Super. 36, 633 A.2d 605 (Pa.Super. 1993), appeal denied, 538 Pa. 663, 649 A.2d 666 (Pa. 1994); Nagy v. Bell Telephone Co., 292 Pa. Super. 24, 436 A.2d 701 (Pa.Super. 1981). In all cases, a Plaintiff who alleges negligent infliction of emotional distress must suffer immediate and substantial physical harm. Were there no such limitations placed on the theory of negligent infliction of emotion distress, then any conduct that causes emotional upset to another would support a cause of action and a law suit. This could include any suggestion or advice given to one person by another, whether solicited or not, which the recipient finds upsetting.