What is the test for establishing fraud against a third party?

To establish fraud there must be clear and convincing evidence showing that (1) false representations were made; (2) with knowledge of their falsity; (3) in contemplation of the other party's reliance upon these false representations; (4) which were, in fact, relied upon. Hawaii's Thousand Friends v. Anderson, 70 Haw. 276, 286, 768 P.2d 1293, 1301 (1989). In addition, the injured party must prove he suffered substantial pecuniary damages. Id.

A. Elements of Fraud