In McCamish, Martin, Brown & Loeffler v. F.E. Appling Interests, 991 S.W.2d 787 (Tex. 1999) the court held that under Texas law, an attorney may be liable to a non-client for making a false statement of material fact to a known person who justifiably relies on the false statement, even if the attorney's purpose is to advance his client's interests. McCamish, 991 S.W.2d at 794-95. In McCamish, the McCamish law firm represented Victoria Savings Association ("VSA..). Id. at 788. VSA was attempting to reach a settlement agreement with Boca Chica Development Company, but the managing partner of Boca Chica refused to sign the settlement agreement unless the law firm affirmed that the settle-ment agreement had "been approved by the Board of Directors of VSA . . . Id. Ralph Lopez, a McCamish attorney, assured Boca Chica's managing partner that the VSA Board of Directors had approved the settlement agreement. Id. In fact, VSA's Board of Directors had not approved the agreement. Id. As a result of Lopez's misrepresentation, Boca Chica did not receive the benefit of the settlement agreement and sued McCamish for negligent misrepresentation. Id. at 789-90. The Supreme Court determined whether a law firm representing a financial institution owed a duty to non-clients for the tort of negligent misrepresentation. McCamish, 991 S.W.2d at 788. The non-clients sued the law firm, claiming the firm negligently misrepresented that the financial institution's board of direc-tors had approved a settlement agreement. Id. at 790. The firm filed a motion for summary judgment, alleging that it did not owe a duty to third parties because there was no privity. Id. The trial court granted the motion, but the court of appeals reversed, holding that even absent privity, an attorney may owe a duty to avoid negligent misrepresentation to a third party. Id. The Supreme Court then examined whether privity was required under Section 552 in order for a non-client to sue an attorney. First, the Court decided that Section 552 applies to attorneys. Id. It then explained that Section 552 imposes a duty to avoid negligent misrepresentation absent privity because the claim is not equivalent to a legal malpractice claim. Id. at 792. "Under the tort of negligent misrepresentation, liability is not based on the breach of duty a profes-sional owes his or her clients or others in privity, but on an independent duty to the nonclient based on the professional's manifest awareness of the nonclient's reliance on the misrepresentation and the professional's intention that the nonclient so rely." Id. at 792. Although an attorney may be subject to liability for negligent misrepresentation under Section 552(1), liability is limited by Section 552(2) to those: "Situations in which the attorney who provides the information is aware of the nonclient and intends that the nonclient rely on the information. In other words, a section 552 cause of action is available only when information is transferred by an attorney to a known party for a known purpose." Id. at 794. The supreme court held that, under certain limited circumstances, a nonclient may bring a Restatement of Torts section 552 negligent misrepresentation claim against an attorney. The McCamish court explained that, with respect to a section 552 suit between a nonclient and an attorney, "a typical negligent misrepresentation case involves one party to a transaction receiving and relying on an evaluation, such as an opinion letter, prepared by another party's attorney." Id. at 793. For example, in McCamish, a nonclient brought a section 552 claim against an attorney based on the attor-ney's representations indicating that a settlement agreement complied with a federal statute. Id. at 789-90. Section 552 provides as follows: One who, in the course of his business, profession or employment, or in any other transaction in which he has a pecuniary interest, supplies false information for the guidance of others in their busi-ness transactions, is subject to liability for pecuniary loss caused to them by their justifiable reliance upon the information, if he fails to exercise reasonable care or competence in obtaining or communi-cating the information. RESTATEMENT (SECOND) OF TORTS 552(1) (1977). The McCamish court also pointed out that the nature of the relationship between the attorney and the nonclient is significant when determining whether a nonclient may successfully bring a section 552 claim against an attorney. In this regard, the court wrote: "Generally, courts have acknowledged that a third party's reliance on an attorney's representation is not justified when the representation takes place in an adversarial context. This adversary concept reflects the notion that an attorney, hired by a client for the benefit and protection of the client's inter-ests, must pursue those interests with undivided loyalty (within the confines of the Texas Disciplinary Rules of Professional Conduct), without the imposition of a conflicting duty to a nonclient whose interests are adverse to the client. Because not every situation is clearly defined as adversarial or nonadversarial, the characterization of the inter-party relationship should be guided, at least in part, by the extent to which the interests of the client and the third party are consistent with each other." Id. at 794