California, United States of America
The following excerpt is from Friddle v. Epstein, 16 Cal.App.4th 1649, 21 Cal.Rptr.2d 85 (Cal. App. 1993):
We hold that an actionable violation of section 632 does not require disclosure of a confidential communication to a third party. 8 (See Kimmel v. Goland (1990) 51 Cal.3d 202, 209-212, 271 Cal.Rptr. 191, 793 P.2d 524.)
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