What is the test for damages under the principle of pure economic loss simpliciter?

30 This case addresses what Taylor J.A., in Kripps, above, called "pure economic loss simpliciter". No one has suffered injury to person or physical damage to property, nor was there risk of such injury or property damage to anyone. Taylor J.A. stated at 290: It is plainly impossible that a right to recovery under the principle in Donoghue v. Stevenson based on a general duty to take care to avoid causing foreseeable damage can arise in cases where the only foreseeable damage is pure economic loss simpliciter. The necessary element of "neighbourhood" or "proximity" cannot be found in cases of this sort, as it normally is in cases of personal injury and physical property damage, solely because the loss was a direct, foreseeable result of the defendant's act or omission. Something else will be required, in addition to the fact that the loss suffered was a direct and foreseeable result of the defendant's conduct, in order to establish the necessary relationship of proximity or neighbourhood.