In Union Oil Co. v. Oppen, 501 F.2d 558, 563 (9th Cir. 1974), commercial fisherman brought an action for economic damages under a federal statute against oil companies for discharging raw crude oil over vast stretches of the coastal waters of Southern California. See 501 F.2d at 559-60. The court found that foreseeability was the crucial determinant as to whether the defendants owed a duty to the commercial fishermen to refrain from negligent conduct in their drilling operations. See id. at 568-69. Therefore, the issue that had to be addressed was "whether the defendants could reasonably have foreseen that negligently conducted drilling operations might diminish aquatic life and thus injure the business of commercial fishermen." Id. at 569. The federal circuit court concluded that the defendants could have reasonably foreseen that the negligently conducted drilling operations might diminish aquatic life and injure the commercial fishermen's business. See id. The court reasoned that the dangers of pollution were known to all, and that the defendants understood the risks of their business. See id. Accordingly, the federal court held that the commercial fishermen had a cause of action to prove their case, and that the defendants were under a duty to commercial fisherman to conduct their drilling and production in a reasonably prudent manner so as to avoid the negligent diminution of aquatic life. See id. at 569-70. The court further noted that the plaintiff's injury was a pecuniary loss of a particular and special nature, limited to commercial fishermen. See id. at 570.