California, United States of America
The following excerpt is from Hooked Media Grp., Inc. v. Apple Inc., H044395, H044782 (Cal. App. 2020):
the promises were made. Summary adjudication was therefore proper on the fraud cause of action. As there is no recognized cause of action for a negligent misrepresentation based on a false promise, summary adjudication was properly granted on that basis, as well. (Tarmann v. State Farm Mut. Auto. Ins. Co., supra, 2 Cal.App.4th 153, 159.)
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