What is the current state of the law on the doctrine of "indirect fraud"?

Plaintiff also devotes several pages of briefing to a description of cases in different factual scenarios, where the courts have applied the principle that a defendant "will not escape liability if he makes a misrepresentation to one person intending that it be repeated and acted upon by the plaintiff," and "if defendant makes the representation to a particular class of persons, he is deemed to have deceived everyone in that class." (Geernaert v. Mitchell (1995) 31 Cal.App.4th 601, 605, 608-609 [seller of real property may be liable to a subsequent purchaser for "indirect fraud" where it was alleged he misrepresented or failed to disclose known material facts about soil subsidence and structural problems to his immediate purchaser, and "either

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intended or expected that the misrepresentations would be repeated and/or the nondisclosures be transmitted to plaintiffs"].)