Is reasonable reliance an essential element of a cause of action for negligent misrepresentation involving physical harm?

Respondents cited Garcia v. Superior Court, supra, 50 Cal.3d 728, 268 Cal.Rptr. 779, 789 P.2d 960 as authority that reasonable reliance is an essential element of a cause of action for negligent misrepresentation involving physical harm. They apparently interpret this as a requirement that the appellant relied on the misrepresentation. The Restatement, however, makes it clear that a plaintiff need not rely on the misrepresentation and may, indeed, not even know that it was made. (See Rest.2d Torts, 311, com. d, illus. 8, pp. 108-109.) The same is true in cases of intentional misrepresentation in which the injured plaintiff was not the person to whom the misrepresentation was made. (See Rest.2d Torts, 310, com. c, pp. 104-105.)